Finding 524098 (2023-005)

Finding 2023-005 – Allowable Costs/Cost Principles (Indirect Cost Rate) Federal Agency: Department of Health and Human Services Federal program title: Block Grants for Community Mental Health Services Assistance Listing Number: 93.958 Pass-Through Agency: Illinois Department of Human Services Pass-Through Number: 45CBB04278; 45CBB03514; 45CBB00648 Award Period: 07/01/2022 – 06/30/2023 Type of Finding: Material weakness in internal control over compliance Criteria or specific requirement: Appendix IV to Part 200—Indirect (F&A) Costs Identification and Assignment, and Rate Determination for Nonprofit Organizations - Section C. Negotiation and Approval of Indirect Cost Rates - Subsection 2. Negotiation and approval of Rates - Clauses "c:" Unless approved by the cognizant agency for indirect costs in accordance with § 200.414(g), organizations that have previously established indirect cost rates must submit a new indirect cost proposal to the cognizant agency for indirect costs within six months after the close of each fiscal year; and "g:" The results of each negotiation must be formalized in a written agreement between the cognizant agency for indirect costs and the nonprofit organization. The cognizant agency for indirect costs must make available copies of the agreement to all concerned Federal agencies. Condition: The Organization requested reimbursement for indirect costs for a twelve-month period in which its indirect cost rate had expired. Questioned Costs: None. Context: The Organization's indirect cost rate expired on June 30, 2022; however, the Organization did not become aware of this or request an extension until June 2023. In August 2023, the Cognizant Agency for indirect costs (the Agency) did provide written notice to the Organization that it could continue using its previous indirect cost rate until the Agency completed its review of the Organization's new indirect cost rate proposal and a new rate could be established. Cause: Staff turnover. Effect: Potential unallowable costs could be charged to and reimbursed by the grant. Repeat Finding: No Recommendation: Management should refine its processes and controls over indirect costs to more closely monitor whether indirect costs being allocated to a grant are based on its current federally negotiated indirect cost rate. This may include identifying the expiration date of the Organization's indirect cost rate during the grant budget preparation process and requesting an extension before the rate expires, or preparing and submitting a new indirect cost rate proposal at the earliest opportunity. Views of responsible officials: There is no disagreement with the audit finding.