Finding 970188 (2022-002)

Significant Deficiency
Requirement
B
Questioned Costs
$1
Year
2022
Accepted
2024-04-18

AI Summary

  • Core Issue: Rental payments between the Agency and its subsidiary exceeded allowable amounts under 2 CFR 200.465.
  • Impacted Requirements: Costs included unallowable items like loan principal and future repairs, leading to non-compliance.
  • Recommended Follow-up: Review and amend the lease agreement to reflect only allowable costs and reconcile payments to identify any amounts owed back to the grantor.

Finding Text

Criteria: Rents paid between the Agency and its subsidiary resulted in amounts charged to the program in amounts greater than the allowable amounts based on 2 CFR 200.465. Condition: The Agency leases office space from its subsidiary, Capital Area Community Action Agency Holdings, Inc. (Holdings). Rental payments are based on a set monthly rate. However, rental costs under less-than-arm's-length leases are allowable only up to the amount of actual costs incurred to own the property. This amount would include expenses such as depreciation, maintenance, taxes, and insurance. Management calculation of rental costs included unallowable components such as loan principle, future planned repairs and maintenance, and the amortization of a future loan payment. These costs are not allowable under 2 CFR 200. Questioned Costs: $20,679 Effect: The Agency is out of compliance with the allowable costs principles concerning related party rental payments. Cause: Management's interpretation of the allowable costs principles included various other costs such as principal payments, future repairs, and the amortization of future principle payments. Recommendation: The Agency should review its lease agreement and reconcile payments made to Holdings for allowable expenditures and determine if any amounts are due back to the grantor. The Agency should also amend their lease agreement to include only allowable costs. Management's Response: See the Management's Response to Findings section for management's detailed response to item 2022-002.

Categories

Questioned Costs Allowable Costs / Cost Principles

Other Findings in this Audit

  • 393745 2022-001
    Material Weakness
  • 393746 2022-002
    Significant Deficiency
  • 393747 2022-003
    Significant Deficiency
  • 393748 2022-004
    Significant Deficiency Repeat
  • 393749 2022-005
    Significant Deficiency Repeat
  • 393750 2022-006
    Significant Deficiency Repeat
  • 970187 2022-001
    Material Weakness
  • 970189 2022-003
    Significant Deficiency
  • 970190 2022-004
    Significant Deficiency Repeat
  • 970191 2022-005
    Significant Deficiency Repeat
  • 970192 2022-006
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
93.568 Low-Income Home Energy Assistance $1.46M
10.558 Child and Adult Care Food Program $259,573
81.042 Weatherization Assistance for Low-Income Persons $154,138
93.600 Head Start $149,013
97.024 Emergency Food and Shelter National Board Program $600
93.569 Community Services Block Grant $591