Finding 538848 (2024-001)

Recommendation We recommend that the Company maintain controls to ensure that the expenses reported to the awarding agency only include allowable amounts and that a duplication of benefits analysis is performed prior to the grants being obligated, if applicable. View of Responsible Officials Management acknowledges the finding and has an established duplication of benefits review process to ensure that only allowable costs are reported to the awarding agency. The Company notes that the initial duplication of benefits guidance was released at the same time as the submission of the costs related to this grant. Our understanding was that such funds were obligated prior to FEMA’s duplication of benefits analysis review due to the initial documentation provided. FEMA subsequently released clarified guidance in December 2023 and determined that it would require a duplication of benefits analysis for all of the costs submitted. We submitted our duplication of benefit analysis based on an analysis that we believed was reasonable, but it was ultimately determined by FEMA that the initial analysis needed to be revised. As a result, in December 2024, we agreed to reduce our project requests, which resulted in the de-obligation of certain costs related to this specific grant/project.