Finding Text
Internal Controls over Allowable Costs Federal Department ? U.S. Small Business Administration Shuttered Venue Operators Grant Program, Federal Assistance Listing # 59.075 Finding 2022 ? 001 Questioned Costs: None Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management Section 200.303 Internal controls states ?The non-Federal? entity must: (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award. Per the U.S. Small Business Administration (SBA) Notice of Award Form-1222 Addendum for the Shuttered Venue Operators Grant (SVOG), the Theatre is not eligible for a Restaurant Revitalization Fund (RRF) grant. In addition, the Theater must close out its grant within 120 days of the end of the budget period (May 3, 2023). At closeout, grantees will provide a reconciliation of expenses by allowable budget category in response to the expense report action item. Grantees should maintain justification for any changes from the final budget to the expense report and maintain clear records of the costs charged to the SVOG award substantiating eligibility and allowability. In addition, per the SBA?s website, Cross-program eligibility guidance, RRF applicant or entities that have a pending application for or received an RRF are not eligible to apply for SVOG. Condition During the current audit period, the Theatre did not maintain adequate controls over determining allowable costs related to its federally funded SVOG program. We consider this to be a significant deficiency in internal controls over compliance with major program requirements. Context During our test of expenditures related to the SVOG grant, we noted the supporting detail underlying the initial schedule of federal awards (SFA) provided to us erroneously included $51,241 of expenditures related to Actors? Inn (a recipient of the RRF program). These expenditures were appropriately excluded from the final SFA. SECTION III-FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (continued) Internal Controls over Allowable Costs Federal Department ? U.S. Small Business Administration Shuttered Venue Operators Grant Program, Federal Assistance Listing # 59.075 Finding 2022 ? 001 (continued) Identification of Repeated Finding None. Effect Inadequate controls over determining and monitoring allowable costs could result in unallowable and questioned costs charged to federal programs. Cause Based on discussions with management, this was primarily due to oversight in the review of expenditures charged to the grant. Recommendation We recommend the Theatre implement procedures to ensure grant expenditures and allowable cost requirements are understood and reviewed in a timely manner. Views of Responsible Officials and Planned Corrective Actions Management agrees with the recommendation. See corrective action plan on page 35.