Finding Text
Finding - The District charged Federal programs for health insurance program premium costs totaling $496,203 for several Federally funded employees who did not participate in the health insurance program, resulting in Federal program questioned costs of that amount.
Criteria - Title 2, Section 200.403, Code of Federal Regulations (CFR), provides that, for an expenditure to be allowable under Federal awards, costs must be necessary and reasonable for the performance of the Federal award and must be adequately documented. Title 2, Section 200.431, CFR, provides that the costs of fringe benefits, including employee insurance, are allowable provided that the benefits are reasonable and required by law, District-employee agreement, or an established policy of the District.
Condition - For the 2023-24 fiscal year, the District provided an employee health insurance program as an employee fringe benefit for program participants and the Board authorized District contributions for individual and family coverage, including contributions for Federally funded employees. The District recorded health insurance premium expenditures each pay period for each employee; however, several Federally funded employees did not participate in the health insurance program. Consequently, the Federal programs should not have incurred health insurance costs for those employees.
Based on our discussions with District personnel and examination of District records, we found that the health insurance premium costs for Federally funded employees who did not participate in the health insurance program totaled $496,203.
Cause - District personnel indicated that they did not monitor the health insurance program participants and related expenditures to ensure that the premium costs were only recorded for health insurance program participants. District personnel also agreed with the questioned costs calculations.
Effect - The District did not comply with Federal regulations that require all Federal expenditures to represent reasonable and necessary charges. Consequently, the CNC incurred questioned costs totaling $306,926, the SEC incurred questioned costs totaling $108,444, and the Title I Program incurred questioned costs totaling $80,833.
Recommendation - The District should establish effective procedures for monitoring the health insurance program participants and related expenditures to ensure that premium costs are only recorded for program participants. Also, the District should document to the respective grantors the allowability of the questioned costs totaling $496,203 or restore these moneys to the appropriate Federal programs.
District Response - The District agrees with the finding. We will work with DOE and other district finance officers to ensure processes going forward are accurate and appropriate with no programs being overcharged.