Finding Text
Finding 2023-001: Cost Allocation Plan Documentation (Significant Deficiency)
Condition:
The Organization uses a Cost Allocation Plan to allocate certain shared direct costs between federal programs. This is specifically allowed by CalOES, the state department that administers the Organization’s Crime Victim Assistance and Family Violence Prevention and Services grants. According to CalOES guidance, shared costs may be allocated based on percentage of time spent on each grant (for payroll costs) or percentage of use (for regular operating expenses). Although the Organization maintains and follows a written Cost Allocation Plan, there is a lack of sufficient calculation documentation to support the amounts allocated between grants under the Plan. Additionally, certain aspects of the Plan itself are vague and could be clarified to allow for more efficient and accurate allocations.
Criteria:
The OMB requires that costs allocated to federal awards be calculated in conformity with generally accepted accounting principles and be given consistent accounting treatment within and between accounting periods.
Cause and Effect:
There are no questioned costs as a result of this deficiency. However, without a clearly defined Cost Allocation Plan, shared direct costs may not be allocated appropriately or consistently between federal programs and accounting periods. Without sufficient calculation documentation to support allocations, the Organization may not recognize errors or potential improvements within their methodology.
Recommendation:
We recommend that the Organization review its current Cost Allocation Plan and ensure that it includes sufficient detail to enable staff to allocate shared direct costs appropriately between all federally funded programs. Specifically, given the number and significance of the CalOES grants that the Organization manages, we recommend that the Organization consider allocating costs by individual grant, rather than by overall program type. We also recommend that client implement procedures to ensure that clear calculation documentation is maintained for every invoice or paycheck that gets allocated across multiple programs.
Views of Responsible Officials and Planned Corrective Actions:
The Organization agrees with the finding and related recommendations and intends to implement them going forward.