Finding 7849 (2023-001)

Criteria or Specific Requirement: According to Code of Federal Regulations, 200 CFR 200.68, the recipient must exclude rental costs from the Modified Total Direct Costs (MTDC) subject to the indirect cost rate. Condition: $64,000 rent ($8,000 a month from July 2022 to February 2023) was included in the MTDC calculation subject the indirect cost rate. When the error was discovered in March 2023, a credit was issued against the March invoice to offset the indirect costs that should not have been previously invoiced. Questioned Costs: $6,400 (known) Context: $64,000 rent ($8,000 a month from July 2022 to February 2023) was included in the MTDC calculation subject the indirect cost rate. Cause: MTDC calculation did not exclude rental costs. Effect: The condition identified led to noncompliance with respect to reimbursement of the rent at the 10% de minimis indirect cost rate. Repeat Finding: Yes Recommendation: We recommend the Blood Bank implement procedures to ensure only allowable charges outlined within 200 CFR 200.68 are included in the MTDC subject to the indirect cost rate.