Finding 528728 (2024-002)

Significant Deficiency
Requirement
BCG
Questioned Costs
$1
Year
2024
Accepted
2025-03-19

AI Summary

  • Core Issue: Inadequate review of grant agreements led to incorrect reimbursement rates, risking compliance with federal requirements.
  • Impacted Requirements: This affects compliance with Allowable Costs, Cost Principles, and Matching criteria under federal guidelines.
  • Recommended Follow-up: Strengthen internal controls by ensuring monthly reviews of reimbursement rates during the month-end close process.

Finding Text

Finding 2024-002: Matching Major Federal Program – Federal Transit Cluster Compliance Requirements: Allowable Costs and Cost Principles, Cash Management, Matching Criteria: In accordance with the grant agreement and Uniform Guidance, effective internal controls must be in place to prevent and detect noncompliance. This requirement extends to costs requested for reimbursement under federal grants. Condition: (X) Compliance Finding (X) Significant Deficiency ( ) Material Weakness Context/Cause: Grant agreements were not reviewed in enough detail to assess appropriateness of rate being charged to the major program prior to submission of request for reimbursement. Request for reimbursement was up to 51% of total expenses incurred but instead a reimbursement rate of 80% was used for grant 2017-001. Effect and Questioned Costs: The absence of detailed review related to cost reimbursement rates significantly increases the risk that misstatements due to error or fraud may occur and not be detected timely. Known questioned costs are $613,075. Likely questioned costs are indeterminable. Recommendation: Management should reinforce the internal controls in place to ensure all reimbursement rates are reviewed on a monthly basis as part of the month end close process prior to grant billing. Responsible Official’s Response: See Corrective Action Plan

Corrective Action Plan

Finding 2024-002: Matching Major Federal Program: Federal Transit Cluster Compliance Requirements: Allowable Costs and Cost Principles, Cash Management, Matching Response: Concur: An inaccurate reimbursement rate was applied causing overpayment of $613,075. Due to the inaccuracy of the percentage rate applied in this drawdown, Trinity Metro will actively reinforce its internal control processes to ensure detailed reviews related to cost reimbursement rates are accurately identified monthly by those who are authorized to process drawdowns. Implementation will take place immediately. Steps that will be taken include: 􀁸 Dual-Approval Process for Reimbursement Requests: Both the Grants Department and Accounting will confirm the accuracy of the reimbursement rate before submission. 􀁸 Grant Agreement Review Process: Both the Grants Department and Accounting will jointly review grant agreements before submitting reimbursement requests to ensure that the correct rate if applied. Date of Completion: This action plan will go into effect immediately. Person Responsible to Ensure Completion: Contact Person: Greg Jordan, Chief Financial Officer Contact Person: Eva Williams, Director of Budget and Grants, Finance

Categories

Questioned Costs Allowable Costs / Cost Principles Cash Management Material Weakness Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1105170 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
20.507 Federal Transit_formula Grants $6.26M
20.500 Federal Transit_capital Investment Grants $1.69M
97.075 Rail and Transit Security Grant Program $245,758
20.513 Enhanced Mobility of Seniors and Individuals with Disabilities $149,204