Finding Text
Federal Agency: Department of Justice
Federal Assistance Listing Number: 16.756
Program: Court Appointed Special Advocates
Award Number: 15JDP-21-GK-02762-CASA
Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under federal awards, they must be adequately documented and there must be sufficient documentation.
“Except where otherwise authorized by statute, costs must meet the following general criteria in
order to be allowable under federal awards:
a) Be necessary and reasonable for the performance of the federal award and be allocable thereto under these principles.
b) Conform to any limitations or exclusions set forth in these principles or in the federal award as to types or amount of cost items.
c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity.
d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.
e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part.
f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b).
g) Be adequately documented. See also §200.300 through §200.309.
h) Cost must be incurred during the approved budget period. The federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).”
Condition: National CASA/GAL allocated expenditures to programs during 2023 based on a direct allocation methodology. This allocation is done manually, and the support was inconsistently maintained. During our testing of costs (excluding salaries), we noted in accordance with §200.403(g) that:
• 4 of 60 transactions was partially charged in the incorrect fiscal period, though within the period of performance. The cost of these 4 transactions were $5,246.
• 2 of 60 transactions had an error in the allocation rate utilized. The cost of these 8 transactions were $33.
• 4 of 60 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 (journal entries).
Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of allocation methodologies, National CASA/GAL could incorrectly charge expenditures to the federal programs.
Known Questioned Costs: $5,279
Likely Questioned Costs: $131,271
Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs in 2023 were $3,612,154. The sample tested consisted of 60 transactions totaling $145,247. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations.
Identification as a Repeat Finding: 2022-004 and 2022-008.
Recommendation: We recommend that policies and procedures be updated to ensure underlying support, as well as support for allocations, is appropriately maintained as required by §200.403.
Views of Responsible Officials: Management concurs with the finding that documentation of support and allocation of costs should be maintained. Policies and procedures were enhanced in 2023 and through 2024 to ensure compliance.