Finding Text
Finding 2022-008 Program Affected :66.818 Brownfields Assessment and Cleanup Cooperative Agreements U.S. Environmental Protection Agency Contract year: 2022 Federal Award Identification Number (FAIN): 00A00664 / 00A00676 / 00A00909 Criteria: 2 CFR ?200.434(c) specifies that "services donated or volunteered to the non-Federal entity ... may not be charged to the Federal award either as a direct or indirect cost." Condition and Context: In determining the population of payroll costs to test under the agreement, we determined the Organization charged $47,480 to the federal award related to unpaid volunteer time. The Organization imputed rates ranging from $35 to $50 per hour to volunteer labor and included this as reimbursable costs in billings to the federal agency. In our nonstatistical sample of 18 payroll transactions, we observed that 12 of them related to unpaid volunteers. Cause and Effect: The Organization does not have internal processes to properly identify costs related to the major federal program. The Organization does not have experience related to expending federal awards and did not properly obtain an understanding of what costs are allowable under the federal award. As a result, the Organization charged unallowable costs to the program. Questioned Costs: $47,480 Identification of Repeat Findings: N/A Recommendation: We recommend the Organization implement a tracking system to identify and report all expenditures of federal awards in compliance with the requirements of the Uniform Guidance. We recommend the Organization obtain training for employees and volunteers in order to gain an understanding of what costs are allowable under federal awards. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. See attached Planned Corrective Actions.