Finding Text
CRITERIA Per CFR 200.405 (a)(1) A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. This standard is met if the cost: (1) Is incurred specifically for the Federal award; (2) Benefits both the Federal award and other work of the non-Federal entity and can be distributed in proportions that may be approximated using reasonable methods; and (3) Is necessary to the overall operation of the non-Federal entity and is assignable in part to the Federal award in accordance with the principles in this subpart. CONDITION During our control and compliance test work over cash management, as well as reconciliation of the Schedule of Federal Expenditures (SEFA), we noted the following: - In testing two of the monthly requests for reimbursement by examining all the invoices related to the reimbursements, we found that there were amounts overbilled that totaled $25,186. - In reconciling the total expenditures on the SEFA, we found that total reimbursement requests exceeded actual expenses incurred by $186,089 (this total includes the $25,186). CAUSE Proper internal control procedures are not maintained to ensure federal reimbursement requests include only actual costs incurred vs budgeted amounts. EFFECT The Organization billed the federal government for amounts of costs that had not yet been incurred and is at-risk for noncompliance with allowable activities and allowable costs, as well as cash management requirements. QUESTIONED COSTS $186,089 CONTEXT Management?s monthly reimbursement requests for the communications and grants technical manager position was based on budgeted amounts and not actual costs incurred. RECOMMENDATION We recommend that management contact the grantor with regard to the overbilled amounts. For future reimbursement requests, only requests funds that are for direct costs incurred and for the approved 10% indirect rate. MANAGEMENT VIEW AND CORRECTIVE ACTION PLAN Corrective action has been taken. FHI has discussed this finding with grantor (USDA Department of Agriculture) as has Auditor. To date, there has been no action taken by the USDA. As of July 2023, FHI has been billing only reimbursable amounts for direct costs incurred and for the approved 10% indirect rate.