Finding 574060 (2024-005)

Significant Deficiency
Requirement
P
Questioned Costs
-
Year
2024
Accepted
2025-08-20
Audit: 364634
Organization: Easter Seals Serving Dc/md/va (MD)
Auditor: Aprio LLP

AI Summary

  • Core Issue: The organization lacks adequate controls to identify and exclude unallowable costs from the indirect cost pool, risking noncompliance with federal regulations.
  • Impacted Requirements: Compliance with 2 CFR 200.403 and 2 CFR 200.412–415, which mandate that only allowable costs be charged to federal awards.
  • Recommended Follow-Up: Enhance accounting systems to flag unallowable costs, establish written procedures, and conduct interim reviews of indirect cost activities.

Finding Text

Finding 2024-005: Reportable finding considered a significant deficiency - Inadequate Controls over Identification of Unallowable Costs in the Indirect Cost Pool Program name: Applies to all federal program utilizing indirect cost rates Assistance Listing: All Federal awarding agency: All Pass-through Entity: All Criteria: In accordance with 2 CFR 200.403 and 2 CFR 200.412–415, costs charged to federal awards, whether direct or indirect, must be allowable under the cost principles of Subpart E. Organizations must have adequate internal controls to identify, segregate, and exclude unallowable costs from charges to federal programs. In particular, indirect cost pools used to calculate rates billed to federal awards must not include unallowable costs such as fundraising, entertainment, or other expressly unallowable expenses. Condition: During our audit procedures, we noted that the Organization does not identify or code unallowable costs (e.g., fundraising event expenses) within its accounting system at the time of transaction entry. As part of our review of the General and Administrative (G&A) cost pool used for indirect cost rate calculations, we identified unallowable costs included in the detailed listing. Per discussion with management, these costs are not intended to be charged to federal awards. Management explained that federal drawdowns are based on a provisional rate and unallowable costs are manually excluded during the closing and cost submission process. Cause: The Organization lacks system-based controls and procedures to flag or segregate unallowable costs during transaction coding. The current process relies heavily on manual review and adjustments at year-end, which increases the risk of unallowable costs being inadvertently included in rates charged to federal programs. Effect: Including unallowable costs in the indirect cost pool—whether or not ultimately billed—represents a significant deficiency in internal control over compliance. Although management asserts that such costs are removed prior to federal reimbursement claims, the absence of preventive controls increases the risk of noncompliance, incorrect cost submissions, and potential disallowed costs during future oversight or audits. Repeat finding: This is not a repeat finding. Questioned costs: None identified as costs were reportedly removed prior to billing; however, the issue represents a control weakness. Perspective: This control deficiency affects the Organization’s system-wide treatment of indirect costs across all federal programs using the provisional rate. Recommendation: We recommend that the Organization: • Implement accounting system enhancements or protocols to flag unallowable costs at the point of entry to ensure proper coding and segregation. • Establish written procedures and staff training to reinforce cost allowability standards under Uniform Guidance. • Consider performing interim reviews of indirect cost pool activity to ensure early identification and removal of unallowable expenses. Management’s response and corrective action plan (unaudited): See corrective action plan.

Categories

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Cash Management

Other Findings in this Audit

  • 574052 2024-003
    Significant Deficiency
  • 574053 2024-004
    Significant Deficiency
  • 574054 2024-005
    Significant Deficiency
  • 574055 2024-005
    Significant Deficiency
  • 574056 2024-005
    Significant Deficiency
  • 574057 2024-005
    Significant Deficiency
  • 574058 2024-003
    Significant Deficiency
  • 574059 2024-004
    Significant Deficiency
  • 1150494 2024-003
    Significant Deficiency
  • 1150495 2024-004
    Significant Deficiency
  • 1150496 2024-005
    Significant Deficiency
  • 1150497 2024-005
    Significant Deficiency
  • 1150498 2024-005
    Significant Deficiency
  • 1150499 2024-005
    Significant Deficiency
  • 1150500 2024-003
    Significant Deficiency
  • 1150501 2024-004
    Significant Deficiency
  • 1150502 2024-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
17.805 Homeless Veterans’ Reintegration Program $790,278
10.558 Child and Adult Care Food Program $319,493
93.493 Congressional Directives $275,526
93.600 Head Start $234,838
93.498 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $97,358
93.575 Child Care and Development Block Grant $50,000
20.513 Enhanced Mobility of Seniors and Individuals with Disabilities $45,059
21.027 Coronavirus State and Local Fiscal Recovery Funds $15,000
93.048 Special Programs for the Aging, Title Iv, and Title Ii, Discretionary Projects $10,824
14.218 Community Development Block Grants/entitlement Grants $0