Finding Text
Criteria: The Code of Federal Regulations Section 200.414(f) states that non-federal entities may elect
to charge a de minimis rate of 10% of modified total direct costs (MTDC), which may be used indefinitely.
If chosen, this methodology once elected must be used consistently for all federal awards.
Additionally, the Code of Federal Regulations Section 200.303, Internal Controls, states that a
non-federal entity must (a) establish and maintain effective internal control over the federal award that
provides reasonable assurance that the non-federal entity is managing the federal award in compliance
with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: During our testing of indirect costs, we noted that three of the 25 drawdown requests sampled
calculated indirect costs as 10% of total costs instead of calculating indirect costs as 10% of modified
total direct costs, as elected by the Agency, totaling $29. The sample of 25 drawdown requests relates
to multiple awards; however, the three drawdown requests using the incorrect indirect cost rate
calculation relate to two contracts passed through the City of Chicago Department of Family and Support
Services, Global PO 180897 and Global PO 181205.
Cause: When the Agency elected the de minimis rate, the Manager of Grants and Contracts did not update
the indirect cost rate calculation for two contracts to apply the de minimis rate.
Effect: Management’s controls did not detect and timely correct the error identified in the condition
above allowing the Agency to over-claim indirect costs related to federal awards. This resulted in
noncompliance with federal requirements.
Known Questioned Costs: $537
Context: We tested a sample of 25 items from a population of 492 items, totaling $30,955,994 and found
three exceptions as noted in the condition, resulting in likely questioned costs of $29 and known
questioned costs of $537. This is a condition identified per review of the Agency’s compliance with
specified requirements using a statistically valid sample.
Repeat Finding: This is not a repeated finding.
Recommendation: We recommend the Agency implements policies and procedures in place to address
rate changes applicable to federal grants and have controls in place to ensure those policies and
procedures are followed on a consistent basis.
Views of Responsible Officials: Historically, one small City of Chicago Department of Family and Support
Services award had a lower cap on administrative costs than the Agency’s negotiated indirect cost rate.
As a result, the Agency applied the lower rate of 10% of total costs to that grant. However, when the
Agency’s request to elect the de minimis rate for indirect costs was approved for FY23, the grant’s
administrative cost cap was no longer lower than the indirect costs calculated using the de minimis rate.
At that time, we should have changed our indirect cost calculation methodology, but that change was
not effectively implemented, and this error was not detected due to the very small impact of the error
on revenue.
The performance period of the grant affected by this error concluded on November 30, 2022, and all
active awards are using the correct indirect cost calculation. As soon as this error was detected, the
Agency issued a refund to the funder for the total over-claimed indirect cost amount.