Finding 555374 (2024-001)

Significant Deficiency
Requirement
B
Questioned Costs
$1
Year
2024
Accepted
2025-04-18
Audit: 353994
Organization: Topos Institute (WA)
Auditor: Clark Nuber P S

AI Summary

  • Core Issue: There is a significant deficiency in internal controls over compliance related to allowable costs, leading to unallowable costs being charged to federal awards.
  • Impacted Requirements: Compliance with 2 U.S. CFR 200 and GAAP was not maintained, resulting in improper accounting and allocation of costs.
  • Recommended Follow-Up: Strengthen internal controls and ensure staff are trained on allowable costs to prevent future issues.

Finding Text

Finding 2024-001 Significant deficiency in internal controls over compliance related to allowable costs. Federal Agency: Department of Defense Program Titles: Air Force Defense Research Sciences Program and Research and Technology Development Assistance Listing Number: 12.800 and 12.910 Award Number: All Award Period: September 15, 2020 - September 14, 2026 Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards provides for specific items of cost which are considered to be unallowable. Additionally, that costs must be accounted for in accordance generally accepted accounting principles (GAAP) and be given consistent treatment. Topos Institute’s internal controls over allowable costs failed to remove these items from allowable costs. Condition/Context During testing of allowable costs, there was once instance where unallowable costs were charged to the indirect cost pool. Additionally, two instances where subscription costs were not accounted for in accordance with GAAP and one instance where a service fee was expensed in the incorrect period. Finally, one instance where two items were purchased but only one item was charged to the indirect cost pool, however the full amount of the tax was inappropriately allocated to the indirect cost pool for the Federal awards. Questioned Costs $3,494 Cause The Institute’s operation of internal controls was not sufficient to ensure that no unallowable costs, costs not charged in accordance with GAAP, and cost not allocated equitably were charged to the federal funding. Effect Based on the exception noted in the operation of internal controls, there could exist unallowable costs that were charged to the Federal Award. Repeat Finding This is not a repeat finding. Recommendation We recommend that the Institute ensure current internal controls are communicated to staff charging expenses to federal awards and consider the need for further strengthening internal controls over allowable costs. Views of Responsible Official of Auditee Management concurs with the finding and has provided accompanying corrective action plan.

Corrective Action Plan

Finding Number 2024-001 Contact Persons: Brendan Fong and Beth Williams Topos will follow the following steps: Corrective action planned Anticipated Completion Date Add a step in the month-end close process to include a review of costs at least quarterly (if not monthly) to identify inaccurately coded transactions. Feb-Apr 2025 Create an unallowable cost tag for entries and re-train the Office Manager to better identify unallowable costs at the point of entry. Done Second party review prior to match in QBO for unallowable cost and prepaid identification. Feb 2025 Prepare an initial draft of the indirect cost proposal at fiscal year end (prior to YE close). Nov 2025 Communicate reminder to PIs about internal controls policies and procedures for expenses reimbursed by federal grants, including ensuring all expenses should be made within the period of performance, and getting written approval from program managers for changes. Mar 2025 Topos considers the above steps sufficient and adequate to close the gaps in the coding errors of transactions that may have permitted unallowable costs. These steps will increase the effectiveness of identifying transactions and allow for appropriate tracking of costs. This will remedy the lapse in effectiveness experienced by Topos’ internal controls over allowable costs.

Categories

Questioned Costs Allowable Costs / Cost Principles

Other Findings in this Audit

  • 555375 2024-001
    Significant Deficiency
  • 555376 2024-001
    Significant Deficiency
  • 555377 2024-001
    Significant Deficiency
  • 555378 2024-001
    Significant Deficiency
  • 555379 2024-001
    Significant Deficiency
  • 1131816 2024-001
    Significant Deficiency
  • 1131817 2024-001
    Significant Deficiency
  • 1131818 2024-001
    Significant Deficiency
  • 1131819 2024-001
    Significant Deficiency
  • 1131820 2024-001
    Significant Deficiency
  • 1131821 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
12.910 Research and Technology Development $333,489
12.800 Air Force Defense Research Sciences Program $331,693