Finding Text
Finding Number: 2022-002 Finding Type: Federal award finding Federal Assistance Listing No.: 64.033 Program Name: VA Supportive Services for Veteran Families Program Federal Agency: U.S. Department of Veterans Affairs Pass-Through Entity: Transition Projects, Inc. Grant Number: SSVF 19-ZZ-127 Federal Award Year: 2022 through 2023 Control Deficiency Type: Significant deficiency over compliance Instance of Noncompliance: Yes Compliance Requirement: Allowable costs/cost principles Questioned Costs: None Repeat Finding: No Criteria: In accordance with Title 38, U.S. Code of Federal Regulations, Part 62, Supportive Services for Veteran Families Program, grantees may use up to 10 percent of supportive services grant funds for administrative costs that are allowable, allocable, and reasonable in conducting the work under the supportive services grant. The determination of allowable costs must be made in accordance with the applicable Federal Cost Principles set forth in 2 CFR Part 200. Condition: While the organization had sufficient allocable administrative costs in excess of the amount charged, we noted that such costs were charged at a fixed monthly rate, rather than the amount of allowable administrative costs. Cause: The organization did not have policies and procedures over cost principles establishing the determination of allowable costs in accordance with 2 CFR 200.405 and other applicable Federal Cost Principles. Effect: The organization did not fully comply with the allowable cost principles specified in the Code of Federal Regulations. As a result, there may be charges to awards that were not properly allocated, do not have ad-equate support, and/or were not accorded consistent treatment. Questioned Costs: No known or likely questioned costs greater than $25,000. Audit Recommendation: We recommend that the organization implement procedures over the administration of federal awards, including establishing written policies and procedures to ensure compliance with Uniform Guidance cost principles. Management?s Response: Throughout 2022, MPD had a policy of allocating all administrative cost to departments based on employee head count. Within each department managing grants, administrative costs were then allocated down to each grant based on the number of FTE funded by each program. The headcount calculation was set at the beginning of the year and was not updated during the year, leading to the same overhead allocation month after month. As of April 1, 2023, MPD has adopted a new written policy for administrative cost allocation. Costs that are not allowable for federal grants are flagged both on timecards and on purchasing transactions with a subaccount code that segregates them from overhead allocations. Costs related to facilities ? rent, equipment leases, office insurance, shared supplies, depreciation, etc. ? are now allocated to departments based on the square footage occupancy of each department, calculated using the guidance referenced in 2 CFR 200. Administrative costs that serve the entire organization such as Human Resources, Accounting, outsourced IT support, etc., are allocated to each department based on headcount, as we consider the number of personnel per department to be the best estimate of supporting services required by each team. The Payroll Specialist generates a current employee roster by department at the end of each month, which is used to update the administrative allocation. Once all costs have been allocated to the department level, both facilities and administrative costs are allocated down to individual grants based on the proportion of total wage costs assigned to each grant within the department for that month.