Finding 523149 (2023-003)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2023
Accepted
2025-02-13

AI Summary

  • Core Issue: SMTCCAC charged excess indirect costs to the Community Services Block Grant, exceeding the approved rate of 22% and the budget for administration costs.
  • Impacted Requirements: Compliance with the federal indirect cost rate agreement and cost principles outlined in 2 CFR Part 200.
  • Recommended Follow-Up: Ensure adherence to the approved indirect cost rate, apply the lower of actual or approved rates, and keep general and administrative costs within the approved budget.

Finding Text

Finding Reference: 2023-003 Prior Year Finding: 2022-006 Federal Agency: Department of Health and Human Services Compliance Requirement: Allowable Costs (Indirect Costs) Type of Finding: Material Weakness in Internal Control over Compliance Federal Program: 93.569 – Community Services Block Grant (CSBG) Grant Award: Various Condition/Context: During the testing of indirect cost allocations to federal programs, it was determined that SMTCCAC charged excess indirect costs for programs to the Community Services Block Grant. The actual indirect costs allocated to all programs exceeded the approved provisional federal indirect cost rate of 22%; and was ultimately reported as administration costs within other costs for the grant, which exceeded the CSBG budget line without obtaining approval from the applicable funding agencies. Criteria: On November 13, 2023, the Department of Health and Human Services approved a provisional indirect cost rate of 22% to be applied to total direct salaries and fringe benefit costs related to all federal programs. This rate is applicable to SMTCCAC’s grants, contract, and other agreements covered by 2 CFR 200 for the period effective from December 1, 2020 to June 30, 2024. According to the approved rate agreement, if any federal contract, grant, or other agreement is reimbursing indirect costs by a means other than the approved rate in this agreement, the organization should (1) credit such costs to the affected programs, and (2) apply the approved rate to the appropriate base to identify the proper amount of indirect costs allocable to these programs. Cause: SMTCCAC allocated general and administration costs to the grant based on its monthly calculated indirect cost rate per program, rather than allocating indirect costs to programs which should not exceed the approved provisional rate of 22%. For FY2023, SMTCCAC calculated an actual indirect cost rate of 57.48% and the excess above the approved provisional rate of 22% was charged to CSBG program for all programs. These excess costs were not within the approved budget for the category administration costs. Effect: SMTCCAC allocated indirect costs for programs in excess of the approved provisional rate to the Community Services Block Grant. These costs were in excess of the budget for administration costs, although within the aggregate budget total. Questioned Costs: Based on our assessment using the approved provisional rate, SMTCCAC overallocated indirect costs to the CSBG grant by $385,819, which exceeded the CSBG budget line category for administration costs. Recommendation: We recommend that SMTCCAC ensures compliance with the cost principles in 2 CFR Part 200, Subpart E, adhere to the approved federal indirect cost rate agreement, and properly apply either the actual annual indirect cost rate or the approved federal rate, whichever is lower, when determining indirect costs charged to federal awards. In addition, other general and administrative costs charged to CSBG should be within an approved budget for the costs.

Corrective Action Plan

Finding Reference: 2023-003 Views of Responsible Officials and Planned Corrective Actions The Agency agrees with this finding and recommendation as presented. Given this finding, the Agency will review monthly its application of the approved provisional indirect cost rate to all grants, contracts, and other agreements covered by 2 CFR 200. The agency will proceed in the following scope of work:  Ensure indirect chargers follow the applicable cost principles per 2 CFR 200, Appendix IV, and grant agreement.  Receive permission from funders for indirect charges over the allocation of the indirect costs per the grant agreement. Name of the contact person responsible for corrective action: Michael Young, President, (301) 274-4474. Planned completion date for corrective action plan: December 31, 2025

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 523150 2023-002
    Significant Deficiency
  • 523151 2023-002
    Significant Deficiency
  • 523152 2023-002
    Significant Deficiency
  • 523153 2023-002
    Significant Deficiency
  • 523154 2023-002
    Significant Deficiency
  • 523155 2023-002
    Significant Deficiency
  • 523156 2023-002
    Significant Deficiency
  • 523157 2023-002
    Significant Deficiency
  • 523158 2023-002
    Significant Deficiency
  • 523159 2023-002
    Significant Deficiency
  • 523160 2023-002
    Significant Deficiency
  • 523161 2023-002
    Significant Deficiency
  • 523162 2023-002
    Significant Deficiency
  • 523163 2023-002
    Significant Deficiency
  • 523164 2023-002
    Significant Deficiency
  • 523165 2023-002
    Significant Deficiency
  • 523166 2023-002
    Significant Deficiency
  • 523167 2023-004
    Material Weakness Repeat
  • 523168 2023-004
    Material Weakness Repeat
  • 523169 2023-004
    Material Weakness Repeat
  • 523170 2023-003
    Material Weakness Repeat
  • 523171 2023-004
    Material Weakness Repeat
  • 523172 2023-004
    Material Weakness Repeat
  • 523173 2023-004
    Material Weakness Repeat
  • 523174 2023-004
    Material Weakness Repeat
  • 523175 2023-004
    Material Weakness Repeat
  • 523176 2023-004
    Material Weakness Repeat
  • 523177 2023-004
    Material Weakness Repeat
  • 523178 2023-004
    Material Weakness Repeat
  • 523179 2023-004
    Material Weakness Repeat
  • 523180 2023-004
    Material Weakness Repeat
  • 523181 2023-004
    Material Weakness Repeat
  • 523182 2023-004
    Material Weakness Repeat
  • 523183 2023-004
    Material Weakness Repeat
  • 1099591 2023-003
    Material Weakness Repeat
  • 1099592 2023-002
    Significant Deficiency
  • 1099593 2023-002
    Significant Deficiency
  • 1099594 2023-002
    Significant Deficiency
  • 1099595 2023-002
    Significant Deficiency
  • 1099596 2023-002
    Significant Deficiency
  • 1099597 2023-002
    Significant Deficiency
  • 1099598 2023-002
    Significant Deficiency
  • 1099599 2023-002
    Significant Deficiency
  • 1099600 2023-002
    Significant Deficiency
  • 1099601 2023-002
    Significant Deficiency
  • 1099602 2023-002
    Significant Deficiency
  • 1099603 2023-002
    Significant Deficiency
  • 1099604 2023-002
    Significant Deficiency
  • 1099605 2023-002
    Significant Deficiency
  • 1099606 2023-002
    Significant Deficiency
  • 1099607 2023-002
    Significant Deficiency
  • 1099608 2023-002
    Significant Deficiency
  • 1099609 2023-004
    Material Weakness Repeat
  • 1099610 2023-004
    Material Weakness Repeat
  • 1099611 2023-004
    Material Weakness Repeat
  • 1099612 2023-003
    Material Weakness Repeat
  • 1099613 2023-004
    Material Weakness Repeat
  • 1099614 2023-004
    Material Weakness Repeat
  • 1099615 2023-004
    Material Weakness Repeat
  • 1099616 2023-004
    Material Weakness Repeat
  • 1099617 2023-004
    Material Weakness Repeat
  • 1099618 2023-004
    Material Weakness Repeat
  • 1099619 2023-004
    Material Weakness Repeat
  • 1099620 2023-004
    Material Weakness Repeat
  • 1099621 2023-004
    Material Weakness Repeat
  • 1099622 2023-004
    Material Weakness Repeat
  • 1099623 2023-004
    Material Weakness Repeat
  • 1099624 2023-004
    Material Weakness Repeat
  • 1099625 2023-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.568 Low-Income Home Energy Assistance $2.33M
21.023 Emergency Rental Assistance Program $1.55M
93.569 Community Services Block Grant $442,103
14.241 Housing Opportunities for Persons with Aids $118,439
14.218 Community Development Block Grants/entitlement Grants $80,097
21.027 Coronavirus State and Local Fiscal Recovery Funds $73,534
93.570 Community Services Block Grant Discretionary Awards $48,406
10.558 Child and Adult Care Food Program $46,766
93.600 Head Start $36,394
93.499 Low Income Household Water Assistance Program $17,739