FAC Explorer

Finding 566118 (2024-001)

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Requirement
ABN
Questioned Costs
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Year
2024
Accepted
2025-06-24
Audit: 359740
Organization: Battelle Memorial Institute (OH)
Auditor: Deloitte & Touche LLP

AI Summary

  • Core Issue: Limited access to classified contracts prevented a full audit of allowable costs and compliance with federal award requirements.
  • Impacted Requirements: The inability to review classified contracts affects the assessment of allowable expenses and special provisions related to security clearances.
  • Recommended Follow-Up: The Company should consult with external regulators to clarify access limitations and explore alternative solutions for compliance.

Finding Text

Finding Reference Number 2024-001 Qualified Auditor’s Opinion for Allowable Costs and Activities Allowed and Unallowed and Special Tests and Provisions for Research & Development Cluster Due to Material Scope Limitations Criteria: In accordance with 2 CFR 200.508 (d), the auditee must provide the auditor access to personnel, accounts, books, records, supporting documentation, and any other information needed for the auditor to perform the audit required for the schedule of expenditures of federal awards. Condition/Context: During our testing of allowable costs and special tests and provisions, access to classified contracts was restricted. Therefore, we were unable to attain contracts that are deemed to be classified. Consequently, the audit evidence was insufficient to support whether the Company has incurred expenses that are allowable in pursuant with the terms and conditions of federal awards. Further, there was no accessibility to the classified federal award contracts for the determination of whether other special tests and provisions are applicable to these classified contracts. Under the testing for allowable costs, there were approximately 10% of expenses related to classified contracts within the total population. Further, the total classified contract expense amount is nearly two times program materiality. For special tests and provisions, we were unable to attain classified contracts to examine the required level of security clearance for personnel assigned to the projects. Out of the total of 637 federal awards, the Company identified 96 contracts with the requirement of security clearance. Of these 96 contracts, 35 contracts (approximately 36%) were classified. Aside from the requirement for security clearance, we were unable to review other special provisions applicable to classified contracts given restricted access to classified contracts. Cause: The Company acknowledges that classified contracts are subject to confidentiality requirements as mandated by external regulators. Access to classified information within these contracts are strictly limited to authorized auditors who have been granted clearance by relevant regulatory authorities. Effect: Audit conclusion cannot be reached for the Company’s compliance with allowable costs and special tests and provisions. Questioned Cost: Unknown Recommendation: The Company is advised to engage with the external regulators to seek clarification on the scope limitation and explore any possible flexibility or alternative approaches. Views of responsible officials: See Corrective Action Plan.

Corrective Action Plan

Reference: Finding 2024-001 Qualified Auditor’s Opinion for Allowable Costs and Activities Allowed and Unallowed and Special Tests and Provisions for Research & Development Cluster Due to Material Scope Limitations Contact: Erica Classing, Controller; classinge@battelle.org; 614-424-3372 Views of Responsible Officials: Battelle acknowledges the scope limitation is the result of access restrictions to classified contract documents imposed by federal agencies that are beyond Battelle’s control. Battelle does not have the authority to grant auditor access to classified programs without the proper security clearance and program permissions, rather this authority resides with the federal awarding agency, in accordance with applicable federal security regulations. These restrictions prohibited access to classified contracts for required audit procedures in those areas noted in Finding 2024-001. This limitation was only on classified contracts which is a small subset (10%) of Battelle’s total reportable expenditures. Battelle provided all unclassified documentation required to support transactions selected for testing. In addition, Battelle provided all documentation necessary to audit compliance with requirements on all non-classified contracts selected. Management upholds high standards of compliance and transparency and continues to support audit processes to the fullest extent possible. Battelle agrees to explore options to satisfy audit requirements while maintaining compliance with classified contract security regulations. Corrective Action Plan: Summary of finding: During testing of allowable costs and special tests and provisions, access to classified contracts was restricted. The auditor was unable to view federal award documents to determine allowability terms and conditions, security clearance requirements, or other special provisions for sample selections of classified contracts. Consequently, this restriction on access to the source contract document resulted in a material scope limitation for these testing areas. Root cause: Access to classified contracts is subject to confidentiality requirements mandated by external regulators, requiring appropriate security clearance levels and verified need-to-know status. If the classified contract is a special access program, obtaining program-specific approvals from the awarding agency in addition to possessing the appropriate security clearance and need to know is required. There is no guarantee that the federal awarding agency will ultimately grant cleared auditors access to the classified contract. Corrective action: Battelle is taking the following steps to address the finding: • Internal Review: We conducted an internal review of the areas affected by the scope limitation to validate each selection complied with the applicable contractual and regulatory requirements. This action was completed by December 19, 2024 and did not identify any instance of non-compliance with applicable rules, regulations, or contractual requirements. • We have existing monitoring mechanisms in place to ensure compliance in the areas affected by the scope limitation. • Early coordination with external auditor: We are collaborating with our external audit team to identify any classified contract audit selections earlier in the annual audit process. A proactive approach will allow Battelle extra time to engage clients for required approvals to either gain access to the classified information or obtain appropriate alternative audit evidence. In addition, any other related steps that can be completed in advance such as verifying auditor clearance types and levels will be performed early to help mitigate any delays. This corrective action requires the audit firm to provide auditors with the appropriate security clearances. • Engagement with regulatory agencies: We are in dialogue with impacted federal awarding agencies to explore options to provide necessary audit evidence. • Enhanced documentation: We are enhancing our audit support procedures to provide guidelines on how, within the bounds of regulatory restrictions, we can provide access to audit evidence for future audits. Overall Anticipated Implementation Date: December 31, 2025

Categories

Special Tests & Provisions Allowable Costs / Cost Principles Reporting

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
47.RD Office of Polar Programs $52.21M
81.RD National Energy Technology Lab $9.85M
12.RD Chief Information Officer $8.97M
97.RD Transportation Security Administration $5.34M
12.RD Dept of Defense $4.89M
12.RD National Guard Bureau $4.26M
81.255 National Renewable Energy Laboratory $3.57M
12.RD Navy $2.77M
12.RD Defense Advance Research Projects Agency $2.26M
97.RD US Secret Service $2.01M
66.RD Marine Protection $1.58M
93.RD National Institutes of Health $1.42M
20.RD Federal Aviation Administration $1.36M
12.RD Defense Advanced Research Projects Agency $1.20M
12.RD Joint Project Manager for Medical Countermeasures $1.20M
12.RD Combating Terrorism Technical Support Group $1.15M
93.RD Centers for Medicare & Medicaid Services $1.03M
93.RD Centers for Disease Control $967,948
12.RD Intelligence Advanced Research $844,492
97.RD Unmanned Systems Threats $702,162
12.RD Missile Defense Agency $673,058
81.087 Energy Efficiency - Renewable Energy Research and Development $649,197
97.RD Countering Weapons of Mass Destruction Office $592,415
19.RD Bureau of International Organization Affairs $559,386
81.255 Office of Clean Energy Demonstrations $553,509
19.RD Bureau of Diplomatic Security $529,223
97.RD Science and Technology Directorate $497,462
12.RD P309 Window Gridding $487,498
20.RD Federal Railroad Administration $430,928
17.RD Data Integrity, Research, and Evaluation $417,950
12.420 Office of Assistant Secretary of Defense for Health Affairs - Military Medical Research $390,574
81.RD National Nuclear Security Administration $386,427
47.RD Solar Program $379,069
12.RD Strategic Environmental Research and Devel Program $376,177
93.286 National Institutes of Health $372,952
17.RD Office of Job Corps $372,016
12.431 Intelligence Advanced Research $354,968
93.RD Biomed Advanced Research Development Authority $344,715
66.RD National Vehicle and Fuel Emissions Laboratory $340,243
12.RD Dp Potency $329,541
66.RD Office of Pesticide Programs $325,832
66.931 International Financial Assistance Projects - Inter. and Tribal Affairs $315,751
93.077 Family Smoking Prevention and Tobacco Control Act Regulatory Research $314,902
12.RD Joint Program Office $301,411
93.RD National Institute of Health $299,054
81.049 Office of Science Financial Assistance Program $292,496
84.RD Stem Innovation $292,369
43.001 Science $291,098
66.RD Office of Pollution Prevention $262,162
93.RD National Center for Environmental Health $254,261
47.RD Nsf Mri $248,880
47.RD Convergence Accelerator $235,581
12.RD Office of Undersecretary $222,038
93.RD Centers for Disease Control and Prevention $180,530
66.RD Office of Air Quality Planning and Standards $170,156
93.867 National Institutes of Health $164,862
81.086 Conservation Research and Development $164,675
66.509 Science to Achieve Results (star) Program $159,357
12.420 Army - Military Medical Research and Development $146,798
66.511 Office of Land and Emergency Management $130,556
81.089 Fossil Energy and Carbon Management $129,174
12.630 Army - Basic, Applied, and Advanced Research in Science/eng $121,097
10.310 National Institute of Food and Agriculture - Afri $106,774
97.RD Transportation Security Laboratory $88,381
21.RD U.s. Mint $88,125
12.RD Army $87,096
66.RD Oaqps $86,526
81.RD Office of Fossil Energy and Carbon Management $86,373
12.RD Technical Information Center $75,603
16.RD National Institute of Justice $73,670
66.931 Office of International and Tribal Affairs $71,509
12.RD National Geospatial Intelligence Agency $60,500
47.070 Computer and Information Science and Eng $52,072
43.001 Earth Science Division $48,916
47.074 Integrative Research in Biology $48,599
43.RD Nisar $43,511
12.RD Medical Cbrn Countermeasures Defense Consortium $41,156
12.RD Gigagen Work Order 001 $39,676
93.RD Agency for Toxic Substances and Disease $36,729
66.RD Office of Air and Radiation $36,348
47.074 Division of Biological Infrastructure $33,873
12.RD Defense Logistics Agency $32,963
97.RD Chemical Security Analysis Center $31,736
47.076 Division of Graduate Education $28,574
66.RD Homeland Security Research Program $26,285
93.RD National Institute of Environmental Health $22,784
47.078 Polar Programs $21,166
20.RD National Highway Traffic Safety Administration $20,227
66.RD Office of Chemical Safety and Pollution Prevention $19,363
12.RD Joint Requirements Oversight Council $18,676
12.RD Gigagen Work Order 002 $16,028
84.RD Stem Initiatives $16,022
47.RD Rising Voices Ncar $14,522
12.RD Air Force $13,298
81.RD Legacy Management $9,135
47.050 Indigenous Data Sovereign $8,772
97.RD Domestic Nuclear Detection Office $8,751
12.RD Joint Program Executive Office $8,489
47.074 Guided Animal Prevalence Surveillance $7,896
93.RD National Institute of Allergy and Infectious Disease $7,892
81.089 National Energy Technology Lab - Fossil Energy Research and Development $6,628
66.RD Streams IV $5,904
12.RD Defense Intelligence Agency $5,351
93.273 Alcohol Research Programs $5,114
93.077 National Institutes of Health - Family Smoking Prevention and Tobacco Control $5,071
66.RD Center for Environmental Solutions & Emergency Response $5,067
93.RD National Center for Advancing Translational Sciences $4,891
47.074 Biological Sciences $4,304
81.RD Lawrence Berkeley $4,284
47.074 Division of Environmental Biology $3,993
12.910 Defense Advanced Research Projects Agency - Research and Technology Development $3,584
43.RD Goddard Space Flight Center $3,267
12.RD Defense Threat Reduction Agency $2,874
12.RD Classified $2,774
47.074 MacRosystems Biology and Neon-Enabled Science $2,571
47.050 Geosciences $1,784
47.079 Office of International Science and Engineering $1,746
47.074 Neon Terrestrial Sites $1,672
66.RD Homeland Security Research Program $1,619
66.RD Oceanographic Surveying $1,532
43.RD Terrestrial Ecology $1,330
47.RD Uw Icecube Management Support $1,179
15.RD Office of Environmental Policy and Compliance $1,076
43.RD Earth Science Division $1,026
47.RD Nrss $968
43.003 Earth Science - Exploration $816
93.393 National Cancer Institute - Cancer Cause & Prevention Research $793
47.RD Neon $549
12.RD Special Operations Command $478
81.089 Office of Fossil Energy - Fossil Energy Research and Development $422
66.RD Office of Water Assessment and Watershed Protection Division $269
47.RD Waggle Device $257
20.RD Federal Highway Administration $206
66.RD Ambient Monitoring Technology Information Center $193
66.RD National Homeland Security Research Center $167
93.103 Food & Drug Administration $72
66.RD Office of Research and Development $7
66.RD Homeland Security Research Center $-97
12.RD Central Command $-108
93.RD Food & Drug Administration $-646
97.RD Federal Emergency Management Agency $-1,125
12.800 Air Force - Defense Research Sciences Program $-1,227