Finding Text
Finding 2024-002 – Allowable Costs & Activities (Significant Deficiency and Noncompliance)
Information on the Federal Program: U.S. Department of Education, Assistance listing # 84.031
Higher Education Institutional Aid and U.S. Department of Education, Trio Cluster
Criteria: 2 CFR Part 200 Subpart E establishes cost principles to apply in determining costs under
federal awards. Non-federal entities are also required to establish controls over the disbursement
process to ensure compliance with allowable cost requirements.Condition: We selected a sample of 25 non-payroll disbursements each for Title III and Trio
programs and three indirect costs for the Trio program. Of the 25 non-payroll disbursements for
Title III, two expenses were allocated but the portion charged to the grant did not tie back to the
invoice, two expenses were incurred in the prior fiscal year but recorded as current year expenses,
and two types of expenses were not in the applicable budgets.
Of the 25 non-payroll disbursements for the Trio Cluster, one type of expense exceeded the budget
amount and of the three indirect cost calculations, one was not calculated correctly.
Cause: On Title III, the College charged a portion of invoices to the grant but the amount could not
be recalculated based on the invoice; meals and subscriptions were charged to the grant but the
type of expense was not in the budget; and services were performed or orders were placed in the
prior year but recognized as current year expenses.
On the Trio Cluster, and equipment expenses were charged to the Trio grant but exceeded the
grant budget. The indirect cost calculation included previously recorded indirect costs in the base
used to recognize and request reimbursement for allowed percentage.
Effect: The College did not comply with the exceptions noted for allowable cost and activity
requirements.
Questioned Costs: Title III $10,261 and Trio Cluster $4,810.
Recommendation: We recommend the College strengthen its policies and procedures surrounding
non-payroll grant disbursements to ensure disbursements are approved, allowable, and calculations
supported.
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.