Finding Text
Finding number: 2022-003: Allowable Costs/Cost Principles, Period of Performance and
Subreceipient Monitoring, Research & Development Cluster
Criteria: Per Part 6 of the Compliance Supplement, controls need to be designed such that
they would prevent or detect potential noncompliance. Management should
implement control activities through policies.
Condition: ABS Institute does not have documented policies regarding the process and
controls in place surrounding the methodology utilized to allocate costs to grants.
ABS Institute does not have documented policies regarding the process and
controls in place surrounding documenting title, job description and pay rate for
employees.
ABS Institute does not have documented policies regarding the process and
controls in place surrounding the review and approval of credit card purchases
and any other purchases/payments made outside of bill.com system.
ABS Institute does not have documented policies regarding the process and
controls in place surrounding the review and approval of accrued expenses
included in the Schedule of Expenditures of Federal Awards.
ABS Institute does not have documented policies regarding the process and
controls in place surrounding subrecipient monitoring.
Cause: ABS Institute was recently formed, so documentation and implementation of
processes is still in process.
Effect or potential
effect:
Possibility of unallowable costs allocated to grants.
Possibility of grant funds drawn down without documentation to support costs
incurred.
Possibility of subrecipient expending federal funds for unallowable costs. Identification as a
repeat finding:
This is a repeat finding from the immediate previous audits, 2021-003 and 2020-
001.
Recommendation: We recommend that ABS Institute document policies regarding the process and
controls in place related to the areas as noted above.
Views of responsible
official:
ABS Institute is in the process of putting in place the appropriate documentation
with a proposed completion