Finding Text
Finding Reference: 2022-006 Federal Agency: Department of Health and Human Services Compliance Requirement: Allowable Costs (Indirect Costs) Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters Federal Program: 93.600 ? Head Start; 93.569 ? CSBG; Grant Award: Various Condition/Context: During the testing of indirect cost allocations to federal programs, it was determined that SMTCCAC overcharged indirect costs on two of seven federal programs. Head Start, a major program, was one of the two programs with overcharges. The indirect costs charged to the programs exceeded the approved provisional federal indirect cost rate of 31.5% without obtaining approvals from the federal awarding agencies. As a result, an overallocation of indirect expenses was incurred by the effected federal programs. In addition, we found that SMTCCAC applied indirect cost rates inconsistently among programs and failed to calculate an actual indirect cost rate and provide composition of indirect costs for the fiscal year 2022. Criteria: On July 23, 2021, the Department of Health and Human Services approved a provisional indirect cost rate of 31.5% to be applied to total direct salaries and fringe benefit costs related to all federal programs. This rate is applicable to SMTCCAC?s grants, contract, and other agreements covered by 2 CFR 200 for the period effective from December 1, 2020 to June 30, 2023. According to the approved rate agreement, if any federal contract, grant, or other agreement is reimbursing indirect costs by a means other than the approved rate in this agreement, the organization should (1) credit such costs to the affected programs, and (2) apply the approved rate to the appropriate base to identify the proper amount of indirect costs allocable to these programs. Cause: SMTCCAC charged indirect costs to grants based on budgeted amounts per grant agreements instead of allocating indirect costs to programs based on an actual indirect rate for the fiscal year not to exceed its approved provisional indirect cost rate of 31.5%. SMTCCAC didn?t calculate an actual annual indirect cost rate for FY 2022 to compare to the approved provisional rate. The actual rate should have been calculated to determine if it was lower than the approved provisional rate. If lower, the actual rate should have been applied. If higher, the approved provisional rate should have been used. Additionally, indirect cost rates were not consistently applied across the various programs. Effect: Indirect cost rates were inconsistently applied across each federal program. SMTCCAC obtained approval from the ERAP grantor to charge indirect costs in excess of the approved provisional indirect cost rate of 31.5%. However, SMTCCAC allocated indirect costs in excess of the approved provisional rate to two of the six remaining federal programs. The remaining four programs were charged below the approved provisional rate. Questioned Costs: The questioned costs were not determinable because the actual annual indirect cost rate was not calculated. Without the actual rate, we could not determine if the actual rate was lower or higher than the approved provisional rate. However, based on our assessment using the approved provisional rate, the overallocations appear to be material. Recommendation: We recommend that SMTCCAC ensures compliance with the cost principals in 2 CFR Part 200, Subpart E, and follows the approved federal indirect cost rate agreement and calculate the actual annual indirect cost rate when determining indirect costs charged to federal awards. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plans section.