Finding 618297 (2022-004)

Significant Deficiency
Requirement
H
Questioned Costs
-
Year
2022
Accepted
2023-04-25

AI Summary

  • Core Issue: Expenses were charged after the end of grant periods, violating compliance requirements.
  • Impacted Requirements: Non-Federal entities must only charge allowable costs incurred during the grant's period of performance, as per 2 CFR §200.309.
  • Recommended Follow-Up: Revise internal procedures to detect out-of-period expenses and enhance the ERP system to prevent recording costs for expired grants.

Finding Text

2022-004 Internal Controls over Compliance and Compliance with Period of Performance Compliance Requirement Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720FDA20GR00287 July 10, 2020 through November 15, 2021 720FDA20GR00216 July 15, 2020 through January 14, 2021 72DFFP20GR00010 March 1, 2020 through May 31, 2021 Criteria or Specific Requirement: In accordance with 2 CFR ?200.309, a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all obligations incurred under the Federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award as required by ?200.344(b). When used in connection with a non-Federal entity?s utilization of funds under a Federal award, ?obligations? means orders placed for property, services, contracts, and subawards made, and similar transactions during a given period that require payment by the non-Federal entity during the same or a future period as described in ?200.71. Condition: During our testing of the period of performance compliance requirement, we selected twenty-five expense samples specifically for grants that began or ended during the year ended September 30, 2022. We also selected nine grant awards with a grant period end date prior to fiscal year 2022 that had expenses charged during the year ended September 30, 2022. Out of the twenty-five samples selected for testing, we identified one expense sample in the amount of $1,029 that was incurred after the end of the period of performance. Out of the nine grant awards selected for testing, we noted that expenses were either charged and/or reclassified to two grant awards that already expired prior to fiscal year 2022. Grant awards 720FDA20GR00216 and 72DFFP20GR00010 were charged $100,382 and $130,610, respectively, for the year ended September 30, 2022 even though these grants already concluded per their grant terms, prior to fiscal year 2022. The amount of $100,382 was an overspending of an expired grant which was reclassified in fiscal year 2021 and inadvertently reversed back in the fiscal year 2022 with no impact in financial reporting to the donor. The amount of $130,610 was reclassified to grant award 72DFFP20GR00010 from grant award 72DFFP18GR00019 during fiscal year 2022. It was also noted during this testing that CRS?s new ERP system as currently configured does not restrict recording of expenses and adjustments to grant awards that already expired at the sub-ledger levels where the transactions are initiated. Questioned Costs: Expenditures incurred after the end of the period of performance totaled $1,029 and are considered to be known questioned costs. The amount of $100,382 noted above was not claimed from the federal grantor but it should have not been included in the schedule of expenditures of federal awards for the year ended September 30, 2022. Context: BDO?s testing of the period of performance compliance requirement was performed by examining whether the expenses selected specifically for grants that began or ended during the fiscal year 2022 were incurred within the proper period of performance of the award. The total amount of the twenty-five expense items selected for testing was $194,527 out of the total population of $10,470,570. BDO also performed specific period of performance procedures on the nine grant awards with grant period end date prior to fiscal year 2022 that had expenses charged during the year ended September 30, 2022. The total amount of expenditures for the nine grant awards selected for testing was $1,311,595. Samples were selected using a non-statistical approach. Cause: CRS management has documented procedures in place to review expenditures; however, those procedures were not performed to a level of detail to identify expenses that were incurred outside the period of the award. The control procedures are primarily manual as the new ERP system as currently configured does not have capability to restrict recording of expenses and adjustments to expired awards at the sub-ledger levels where the transactions are initiated. Effect: While the known questioned costs that resulted from the conditions identified above were not material to the major program, the lack of adherence to the established internal control procedures around the period of performance of the award can lead to noncompliance with federal statutes, regulations, and the provisions of the grant agreements. This could ultimately result in additional disallowed costs for the major program. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend management revisit and consider revising their internal procedures around detecting expenditures incurred outside of the period of performance of the awards as well as for ensuring that expenses are recorded in the appropriate fiscal year from an accrual basis perspective. We also recommend management work towards enhancing or determining a modification of the ERP system?s capability to restrict the recording of expenses and adjustments to expired awards at the sub-ledger levels where the transactions are initiated. Views of Responsible Officials: CRS management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.

Categories

Subrecipient Monitoring Period of Performance Reporting

Other Findings in this Audit

  • 41851 2022-003
    Significant Deficiency
  • 41852 2022-003
    Significant Deficiency
  • 41853 2022-004
    Significant Deficiency
  • 41854 2022-004
    Significant Deficiency
  • 41855 2022-004
    Significant Deficiency
  • 41856 2022-003
    Significant Deficiency
  • 618293 2022-003
    Significant Deficiency
  • 618294 2022-003
    Significant Deficiency
  • 618295 2022-004
    Significant Deficiency
  • 618296 2022-004
    Significant Deficiency
  • 618298 2022-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
98.009 John Ogonowski Farmer-to-Farmer Program $2.33M
19.523 Covid-19 - Overseas Refugee Assistance Program for South Asia $2.00M
19.520 Overseas Refugee Assistance Programs for Europe $1.85M
19.800 Weapons Removal and Abatement $294,504
93.318 Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security $252,497
93.067 Covid-19 - Global Aids $226,681
93.318 Covid-19 - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security $220,000
98.001 Covid-19 - Usaid Foreign Assistance for Programs Overseas $200,000
10.606 Food for Progress $143,495
93.067 Global Aids $95,581
98.007 Food for Peace Development Assistance Program (dap) $83,516
19.517 Overseas Refugee Assistance Programs for Africa $76,715
17.401 International Labor Programs $65,736
19.345 International Programs to Support Democracy, Human Rights and Labor $40,151
10.619 International Agricultural Education Fellowship Program $21,034
19.017 Environmental and Scientific Partnerships and Programs $15,533
10.608 Food for Education $10,965
19.518 Overseas Refugee Assistance Programs for Western Hemisphere $7,458
19.703 Criminal Justice Systems $7,173
19.523 Overseas Refugee Assistance Program for South Asia $3,398
98.008 Food for Peace Emergency Program (ep) $1,449
10.612 Usda Local and Regional Food Aid Procurement Program $163
98.001 Usaid Foreign Assistance for Programs Overseas $43
19.519 Overseas Refugee Assistance Program for Near East and South Asia $23