Finding Text
2 CFR § 2900.4 gives regulatory effect to the Department of Labor for 2 CFR § 200 Subpart E which outlines allowable costs principles. This guidance provides that for a cost to be allowable, it must (1) be for a purpose the specific award permits and (2) fall within 2 CFR 200 Subpart E - Cost Principles.
We further noted that 20 CFR section 671.140 states the following as allowable activities:
(a) National emergency grants may provide adjustment assistance for eligible dislocated workers, described at WIA section 173(c)(2) or (d)(2).
(b) Adjustment assistance includes the core, intensive, and training services authorized at WIA sections 134(d) and 173. The scope of services to be provided in a particular project are negotiated between the Department and the grantee, taking into account the needs of the target population covered by the grant. The scope of services may be changed through grant modifications, if necessary.
(c) National emergency grants may provide for supportive services to help workers who require such assistance to participate in activities provided for in the grant. Needs-related payments, in support of other employment and training assistance, may be available for the purpose of enabling dislocated workers who are eligible for such payments to participate in programs of training services. Generally, the terms of a grant must be consistent with Local Board policies governing such financial assistance with formula funds (including the payment levels and duration of payments). However, the terms of the grant agreement may diverge from established Local Board policies, in the following instances: (1) If unemployed dislocated workers served by the project are not able to meet the 13 or 8 weeks enrollment in training requirement at WIA section 134(e)(3)(B) because of the lack of formula or emergency grant funds in the State or local area at the time of dislocation, such individuals may be eligible for needs-related payments if they are enrolled in training by the end of the 6th week following the date of the emergency grant award;
(2) Trade-impacted workers who are not eligible for trade readjustment assistance under NAFTA-TAA may be eligible for needs-related payments under a national emergency grant if the worker is enrolled in training by the end of the 16th week following layoff; and
(3) Under other circumstances as specified in the national emergency grant application guidelines.
(d) A national emergency grant to respond to a declared emergency or natural disaster, as defined at § 671.110(e), may provide short-term disaster relief employment for:
(1) Individuals who are temporarily or permanently laid off as a consequence of the disaster;
(2) Dislocated workers; and
(3) Long-term unemployed individuals.
(e) Temporary employment assistance is authorized on disaster projects that provide food, clothing, shelter and other humanitarian assistance for disaster victims; and on projects that perform demolition, cleaning, repair, renovation and reconstruction of damaged and destroyed structures, facilities and lands located within the disaster area. For such temporary jobs, each eligible worker is limited to no more than six months of employment for each single disaster. The amounts, duration and other limitations on wages will be negotiated for each grant.
(f) Additional requirements that apply to national emergency grants, including natural disaster grants, are contained in the application instructions.
During testing of fiscal year 2021, there were costs charged to this grant that were not supported by invoices. The total amount tested that had no invoice support was $14,615 between 7 different checks. Thus, we could not determine if these costs were allowable or not. Failure to maintain adequate support documentation for federal expenditures could result in costs being disallowed by the grantor. Support should be maintained for all expenditures to ensure that each expenditure charged to the program is for an allowable activity/cost. It is likely that the projected expenditure amount is in excess of $25,000 and therefore is considered questioned costs under 2 CFR § 200.516.
In addition to this issue, we could not determine if the expenditures in total for this program were supported by the accounting system records since we could not reconcile between the accounting system and the federal schedule. See Finding 2021-003 above for this issue in detail.