Finding Text
Finding No.: 2023-007
Federal Agency: U.S. Department of the Interior
Pass-Through Entity: Government of Guam
AL Program: 15.875 Economic, Social, and Political Development of the Territories
Area: Period of Performance
Questioned Costs: $113,767
Criteria:
In accordance with applicable period of performance (POP) requirements, a non-federal entity may
charge only allowable costs incurred during a federal award’s period of performance. Unless the
federal awarding agency authorizes an extension, a non-federal entity must liquidate all financial
obligations incurred under the federal award not later than 120 calendar days after the end date of
the period of performance as specified in the terms and conditions of the federal award or in the
approved extension.
Condition:
GDOE charged costs to a federal award after the period of performance ended, as follows:
Subsequently, on August 21, 2024, GDOE provided journal entry GEN 120 to transfer $112,157
from Grant 2016 D16AP00059 to Grant 2021 D21AP0036. However, the corresponding 2016
expenditures were obligated prior to 03/01/2021, which is the POP start date for Grant 2021.
Therefore, GEN 120 does not result in effective corrective action.
No questioned cost is presented for Federal Award No. D15APG0047 and D17AP00103 because
GDOE subsequently recorded journal entries in July 2024 to charge costs appropriately to grant
year 2019.
Cause:
GDOE did not enforce monitoring controls over compliance with applicable period of performance
requirements.
Finding No.: 2023-007, continued
Federal Agency: U.S. Department of the Interior
AL Program: 15.875 Economic, Social, and Political Development of the Territories
Area: Period of Performance
Questioned Costs: $113,767
Effect:
GDOE is in noncompliance with applicable period of performance requirements. The reportable
questioned cost is $113,767.
Recommendation:
Responsible personnel should enforce monitoring controls over compliance with applicable period
of performance requirements. Prior to charging costs to a federal award or liquidating obligations
incurred under a federal award, responsible personnel should verify that the period of performance,
including the liquidation end date, has not expired.
Views of Responsible Officials:
GDOE agrees with the finding. GDOE is in receipt of Department of Interior grants and manages
said funds in coordination with BBMR and Guam Homeland Security. GDOE established projects
that were allowable for the use of these funds on a reimbursement basis. In an effort to maximize
federal funding, GDOE initiated a transfer of expenses which was tied to a purchase order in FY
2016.
Plan of action and completion date:
GDOE Financial Affairs has recorded an adjusting journal entry to record the expenditures under
FY 2021 but will have to reclass the expenditure in to FY 2020. GDOE will assign an accountant
to reconcile GDOE’s Department of Interior budget availability with BBMR and will monitor
AS400 for proper recording of transactions.
Plan to monitor and responsible officials:
The Comptroller (vacant) will monitor on a quarterly basis expenditure from the Department of
Interior grant and will prepare a progress report on a semi-annual basis to the Deputy of Finance
and Administrative Services, Morgan W. Paul, for review and approval.