Finding 573150 (2023-002)

Material Weakness
Requirement
P
Questioned Costs
$1
Year
2023
Accepted
2025-08-08

AI Summary

  • Core Issue: The Organization requested reimbursement for 100% of certain employees' compensation, violating the Assistance Agreement's limit of 92.31%.
  • Impacted Requirements: Compliance with 2 CFR Section 200.400 on allowable cost principles was not met due to outdated agreement terms.
  • Recommended Follow-up: Management should update the Assistance Agreement to reflect all negotiated changes to avoid future compliance issues.

Finding Text

Criteria: 2 CFR Section 200.400 requires allowable cost principles to be followed in accordance with the Assistance Agreement. Condition: The Organization’s Assistance Agreement limited reimbursement of certain employees’ compensation, excluding the Executive Director, to 92.31% of their total compensation. The Organization requested reimbursement for 100% of certain employees’ compensation. Cause: Subsequent to the Assistance Agreement being awarded and finalized, the Organization negotiated with the grantor to remove the compensation limitation; however, the Assistance Agreement was not updated for this change. Effect: Failure to comply with Assistance Agreement. Questioned Costs: Based on the total labor charged, excluding the Executive Director, there are likely questioned costs, which include direct labor, fringe on direct labor, and general and administrative fringe, totaling approximately $180,000. Recommendation: Management should ensure all negotiated agreements are included in the Assistance Agreement.

Corrective Action Plan

As part of the proposal negotiations for the federal program, initial discussions with the sponsoring office of the federal program included a limitation for allowable compensation for employees that were not the Executive Director. Although the limitation was intended to be removed from the final agreement, the budgeted requested salaries were not updated. We will attempt to have the sponsoring office of the federal program to retroactively amend the Assistance Agreement to remove the compensation limitation. The Assistance Agreement has been modified to remove any such limitation prospectively beginning with Modification 0015 April 2024.

Categories

Questioned Costs Allowable Costs / Cost Principles Cash Management

Other Findings in this Audit

  • 573149 2023-001
    Material Weakness
  • 1149591 2023-001
    Material Weakness
  • 1149592 2023-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
81.049 Office of Science Financial Assistance Program $2.91M