Finding Text
Allowable costs - U.S. Department of Agriculture, Department of Social Services, The Emergency Food Assistance (Food Distribution Cluster), Assistance Listing # 10.565, 10.568 & 10.569, June 30, 2022 Award Year, pass-through State of Missouri Department of Health and Senior Services. Criteria: The Administrative cost grant can only be used for activities intrinsic to the processing, transportation and distribution of the Emergency Food Assistance Program (?TEFAP?) commodities, costs associated with determination of eligibility, costs of recordkeeping, auditing or other administrative procedure required for program participation, or costs involved in publishing announcements of times and locations of distribution. Under 2 CFR 200.403, costs must not be included as a cost or used to meet cost sharing or matching requirements of any other federal financed program in either the current or prior period. Under 2 CFR 200.334, non-federal entities are required to retain financial records and supporting documentation for a three-year period from the date of financial reporting to the pass-through entity. Condition: Administrative costs are submitted to the state monthly for reimbursement on the Record of Expenditures under the TEFAP Financial Assistance form (?FD-32D?). The State reimburses the Organization for administrative costs as determined by the state on a monthly basis. Typically, the monthly reimbursement amount is significantly less than the actual amount of allowed administrative expenses incurred by the Organization. During our procedures, we noted that certain expenditures, amounting to approximately $3,290, which were included on the FD-32D of which supporting documentation the Organization is required to retain under 2 CFR part 200 was lacking. As such, we could verify these costs related to activities allowed for reimbursement under 2 CFR part 200. Questioned Costs: None. The monthly reimbursement requests for administrative costs submitted by the Organization exceed the amounts reimbursed by the State and therefore these amounts are not considered to be reimbursed but should not have been included in the monthly submittal as the supporting documentation was unavailable to ensure that the related costs were allowable. Context: Employees with reporting duties for the program are including expenditures that are not substantiated by receipts demonstrating they are allowed under the terms of the grant. Effect: Costs which are possibly unallowable, due to the lack of supporting documentation, are being improperly included on the monthly reporting to the State. It was noted that after excluding these costs from the monthly reports, the actual allowed administrative costs incurred and submitted by the Organization to the State remained greater than the amount reimbursed by the State. Cause: The employees responsible for the preparation of the report did not have the proper information, training and knowledge of the program to ensure that only allowable costs are included on the report. Recommendation: The Organization should review its accounting and reporting policies to ensure that steps are added to include a review for unallowable costs. Identification as a Repeat Finding: This is a repeat of finding 2021-002. Views of Responsible Officials and Corrective Actions See Corrective Action Plan