Finding Text
Finding 2022-010 Program Affected: 66.818 Brownfields Assessment and Cleanup Cooperative Agreements U.S. Environmental Protection Agency Contract year: 2022 FAIN: 00A00664 / 00A00676 / 00A00909 Criteria: 2 CFR ?200.430(i) specifies that "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated..." Condition and Context: The Organization did not maintain documentation of what program the employee or the paid consultant expended time and effort on, and therefore was charging an estimated amount of time to the federal program that is not directly supported by a timecard or invoices. Additionally, the rate charged was not directly calculated based on the rate that the employee and the consultant were paid, but rather the Organization billed the federal program for an estimate which approximated the rate they were paid. During our nonstatistical sampling of costs, we noted 6 of 6 transactions tested were not properly supported. Cause and Effect: The Organization does not have internal processes to properly document and retain records which would appropriately support the amounts charged to the federal grant. The Organization does not have processes in place to properly document and retain the review of the calculation of billings charged to the federal grant. As a result, the Organization would not be able to properly identify unallowable costs charged to the major federal program. Questioned Costs :N/A Identification of Repeat Findings N/A Recommendation : We recommend the Organization bill the major federal program based on actual hours and rates charged by employees and contractors. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding. See attached Planned Corrective Actions.