Finding Text
Federal Agency: Department of Justice
Federal Assistance Listing Numbers: 16.756, 16.726
Programs: Court Appointed Special Advocates, Juvenile Mentoring Program
Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028
Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the federal awarding agency. Unless the federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions.
Condition: National CASA/GAL allocated expenditures to the grant during and after the funding period. During our testing of costs, we noted the below:
For Court Appointed Special Advocates:
• Three of 136 transactions were either fully or partially incurred after the grant period.
• 22 of 136 transactions lacked documentation of review and approval of the allocation of costs made through journal entries.
For Juvenile Mentoring Program:
• 27 of 97 transactions lacked documentation of review and approval of the allocation of costs made through journal entries.
Cause: National CASA/GAL did not have procedures in place to document, and maintain the documentation of, the review and approval of the allocation methodology and the allocation of costs through the journal entry process.
Effect or Potential Effect: Without consistent application of the controls in place to ensure costs are allowable and reimbursable, and properly recognized based on the date of incurrence, National CASA/GAL could incorrectly charge expenditures to the federal programs.
Questioned Costs Court Appointed Special Advocates: Below reporting threshold.
Questioned Costs Juvenile Mentoring Program: None.
Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. For the Court Appointed Special Advocates Program, 16 transactions totaling to $85,362 in costs incurred at the end of the period of performance were tested from a population of 43 transactions totaling to $150,874. Three transactions with costs incurred outside the period of performance were identified totaling $4,917.
Additionally, 120 transactions (60 payroll and 60 non-payroll) were tested from populations of expenditures incurred throughout 2022. Of these, 22 non-payroll transactions, totaling to $15,405, were identified, which lacked documentation of review and approval of the allocation of costs made through journal entries. One non-payroll transaction of $95 was identified lacking relevant supporting documentation.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed.
Views of Responsible Officials: Management concurs with the finding that costs were incurred outside the appropriate funding period. Management will produce and maintain documentation supporting the review and approval of the funding period associated with costs incurred and their proper inclusion in the applicable period. Management will update policies and procedures to periodically review subrecipient details to ensure compliance with funding periods.