Finding Text
Finding Number: 2022-001
Finding Type: Federal award finding and financial statement finding
Federal Assistance Listing No.: 93.591
Program Name: Family Violence Prevention and Services/State Domestic Violence Coalition
Federal Agency: U.S. Department of Health and Human Services
Pass-Through Entity: n/a
Grant Number: 2101ORSDVC
Federal Award Year: 2021
Control Deficiency Type: Material weakness in internal controls over compliance and financial reporting
Instance of Noncompliance: Yes
Compliance Requirement: Allowable costs
Questioned Costs: None over $25,000
Repeat Finding: Yes
Criteria: According to 45 CFR Part 75 Subpart E §75.405 Allocable Costs, a cost is allocable to a particular federal
award in accordance with the relative benefits received. Costs that benefit both the federal award and other
work of the entity should be distributed in proportions that may be approximated using reasonable methods. All
activities which benefit from the costs must receive an appropriate allocation of the costs.
Condition: During the audit, it was noted that costs appearing administrative in nature, i.e., contract accountant,
insurance, dues and memberships, and audit expenses, were charged to the federal award based on the award
budget and were not distributed in an equitable method to all activities that benefited from the costs.
Cause: The Coalition’s understanding is that the award allows 100% of these costs, up to the award budgeted
amount for management and shared expenses, to be charged to the federal award.
Effect: Costs that that benefitted all programs were not distributed in an equitable method to all activities that
benefited from the costs.
Audit Recommendation: We recommend the Coalition develop controls and procedures to correctly allocate
costs to all activities and funding sources that benefited from the costs.
Management’s Response: OCADSV added an Administrative Cost Center to its General Ledger effective 10/01/22,
the beginning of FY23 and began costing administrative payroll cost to that cost center. Additionally, the organization
retrained administrative staff on direct cost allowable activities vs. administrative activities relative to timekeeping
and timesheet preparation and the necessity of daily work descriptions supporting the hourly allocation.
The Payroll policy that requires supervisors to review and sign off on timesheets and hourly allocations to cost
centers was also reviewed.
Audit costs for FY22 will be allocated in accordance with 2 CFR 200.405 requirements. Beginning with FY23 all
accounting and other admin payroll related cost will be allocated to the administration cost center with the exception
of time related to specific grant or other cost center.
FY22 grant expenditures were reviewed post year-end and a line-by-line review was conducted to bring the direct
and indirect expense cumulative total into compliance with audit findings.
Any outstanding reports were adjusted to reflect the adjusted life of grant to current date reporting.
Executive, Financial and Grant Management staff will, during FY24, complete the Online Grants Financial management
Training available at onlinefmt.training.ojp.gov to improve knowledge and compliance with 2 CFR 200
guidance and requirements. The said training will be incorporated into onboarding processes for any newly hired
employee who have direct responsibilities related to grant management and/or reporting.
Effective 6/21/23 and ongoing:
OCADSV is continuing its’ efforts to implement controls and procedures for directly or indirectly allocating costs
to Programs based on the benefit of the cost. Direct allocation is used when a specific budget program line for
funding exists, or where Program(s) can be identified. For indirect cost allocation different allocation methods
may be used, depending on the cost type and only after the Program(s) where the costs benefited are identified.
Financial staff review grant expenditures line by line, using program budgets for additional support, in preparing
quarterly funding reimbursements.