Finding Text
2022 ? 002 Federal Agency: Department of Health and Human Services Federal Program Name: Immunization Research, Demonstration, Public Information and Education, Training and Clinical Skills Improvement Projects Assistance Listing Number: 93.185 Pass-Through Agency: Michigan State University Award Period: July 31, 2021 ? July 30, 2023 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Material Noncompliance (Modified Opinion) Criteria or specific requirement: 2 CFR 200.414(f) states that organizations may elect to charge a de minimis rate of 10% of modified total direct costs (MTDC) which may be used indefinitely. Modified Total Direct Cost (MTDC) is defined as all direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and up to the first $25,000 of each subaward (regardless of the period of performance of the subawards under the award). Condition: Indirect costs were calculated on the full subaward amount, not just the first $25,000. Questioned costs: $50,148 Context: We recalculated the total indirect costs that were billed to the grant, and noted that the 10% indirect cost rate was applied to all subawards, not just the first $25,000 awarded. Cause: Management was not aware of this requirement. Effect: Costs were reimbursed to the Foundation from federal funds related to indirect costs that were not eligible. Recommendation: We recommend the Foundation attend training, review federal requirements, and fully understand the requirements over indirect costs. Views of responsible officials: There is no disagreement with the audit finding. See the Corrective Action Plan for further details.