Finding 597651 (2022-003)

Significant Deficiency
Requirement
BG
Questioned Costs
$1
Year
2022
Accepted
2023-01-04

AI Summary

  • Core Issue: The Agency's method for allocating administrative costs to grants does not comply with federal requirements, leading to questioned costs of $6,365.
  • Impacted Requirements: Non-federal entities must maintain effective internal controls and ensure administrative costs do not exceed 10% of grant funds, as outlined in 2 CFR 200.303(a) and 200.302.
  • Recommended Follow-up: The Agency should implement a compliant indirect cost allocation policy based on actual expenses to avoid future funding risks.

Finding Text

2022-003 Compliance and Internal Controls over Allowable Costs and Earmarking (Significant Deficiency) Assistance Listing Number 64.033 VA Supportive Services for Veteran Families, VA Supportive Services for Veteran Families ? Shallow Subsidy, and COVID ? 19 VA Supportive Services for Veteran Families 2020-2021 and 2021-2022 Funding U.S. Department of Veteran Affairs Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, grantees are required to have a detailed breakout of administrative costs along with any supporting documents for those expenses for auditing and oversight. Title 2 CFR 200.302 requires the financial management system of each non-Federal entity provide records that identify adequately the source and application of funds for federally-funded activities. Furthermore, the grant agreement requires that no more than 10% of supportive services grant funds may be used for administrative costs. Condition: Indirect cost allocation methodology used by the Agency to charge expenses to the grant is not allowable per grant. Additionally, administrative costs charged to closed out grants during the year exceeded the total allowable administrative costs by $6,365. Cause: The Company was charging administrative expenses to the grant based on an internally drafted allocation methodology and not on actual administrative costs incurred, which is not in line with grant agreement. Additionally, with the turnover in the Agency, reconciliation of grant funds received to the maximum allowed administrative costs per the agreement was not performed. Effect: While indirect costs charged to grants may be allowable, these need to be supported by actual expense incurred or the Agency risks elimination of indirect costs from future awards and / or loss of entire award and / or return of unsubstantiated administrative costs to the grantor. Questioned Costs: $6,365 Perspective: Grantor has identified that the Agency?s indirect allocation methodology is not in compliance with award requirements. Methodology as revised by the Agency was still not deemed in compliance. Recommendation: The Agency should establish and follow allowable indirect allocation policy based on identifiable measures. The indirect costs charged to grant should be able to be substantiated by actual costs incurred. Views of Responsible Officials: We concur with the recommendation, please see Corrective Action Plan.

Categories

Questioned Costs Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Other Findings in this Audit

  • 21209 2022-003
    Significant Deficiency
  • 21210 2022-003
    Significant Deficiency
  • 21211 2022-003
    Significant Deficiency
  • 597652 2022-003
    Significant Deficiency
  • 597653 2022-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.023 Covid-19 Emergency Rental Assistance Program $1.33M
64.033 Covid -19 Va Supportive Services for Veteran Families Program $954,023
14.231 Covid-19 Emergency Solutions Grant Program $712,383
14.218 Covid-19 Community Development Block Grants/entitlement Grants $567,028
93.959 Block Grants for Prevention and Treatment of Substance Abuse $382,884
64.033 Va Supportive Services for Veteran Families Program $203,362
14.235 Supportive Housing Program $114,312
14.231 Emergency Solutions Grant Program $106,458
93.959 Women's Block Grants for Prevention and Treatment of Substance Abuse $50,167
64.033 Va Supportive Services for Veteran Families Program - Shallow Subsidy $33,298
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $9,199