Finding Text
Federal Program: AL 20.237 – High Priority Commercial Motor Vehicle Grant Program,
Federal Motor Carrier Safety Administration (FMCSA) Cluster.
Compliance Requirements: Period of Performance.
Type of Finding: Material Noncompliance and Internal Control Over Noncompliance.
Criteria: Per guidance provided by Section 7.5 of the Motor Carrier Safety
Assistance Program – Grant Comprehensive Policy, 49 U.S. Code § 31104(f)(2), and 200 Code of Federal Regulations (“CFR”) Section 200.309, only allowable costs incurred during the period of performance specified in the Notice of Grant Award may be charged to the related federal award.
Condition and Context: On September 30, 2023, IRP prepaid $174,465 for data repository hosting and maintenance services that were not incurred until the quarter ended December 31, 2023. IRP reported this expenditure in Reports SF-425 and requested its reimbursement on form SF-270, for the quarter ended September 30, 2023, and charged the amount to federal award FM-MP- 0580-21. As expenditure occurred during the fiscal year ending September 30, 2024, it should be charged to federal award FM-MHP-0762-23, which has a period of performance from September 1, 2023, to September 30, 2025 per review of the notice of grant award.
Questioned Costs: $174,465.
Cause: Management lacked the appropriate knowledge of the period of performance requirements specified by the federal awarding agency and Uniform Guidance.
Effect or Potential Effect: This error resulted in a $174,465 charge to award FM-MP-0580-21 for services that were incurred outside of the period of performance.
Recommendation: We recommend management implement pre-submission controls, such as requiring date validation for all expenses against the award's period of performance and providing training to educate staff on 2 CFR requirements and period-of-performance limitations. We understand management has alerted FMCSA to the error and intends to work with them to correct the reporting of these expenditures, upon submission to
the Federal Audit Clearinghouse of the data collection form and single audit reporting package for the year ended September 30, 2024.
Views of Responsible Officials: Management acknowledges the finding and concurs with the recommendation. Grant management procedures have been revised to verify that services are received and costs incurred within the authorized period of performance in accordance with 2 CFR § 200.403 before the costs are charged to a federal award. Staff involved in grant management will receive targeted training on 2 CFR requirements related to period-ofperformance compliance and allowable cost timing.