Finding Text
Time Keeping – Material Weakness – Internal Control and Compliance Finding
Criteria
Management has identified an issue pertaining to timekeeping compliance with their proposal response to their Department of State- International Security and Non-Proliferation bureau, Office of Cooperative Threat Reduction (DOS – ISN/CTR) customer. Specifically, certain activities related to preparing or working on proposals for DOS – ISN/CTR were classified as direct payroll costs charged to DOS – ISN/CTR programs, rather than being treated as indirect costs.
Context
CRDF Global works closely with the DOS – ISN/CTR office year-round to provide concepts, rescopes, and new ideas on how best to use to already awarded funds to the organization to execute the DOS – ISN/CTR’s mission. The labor for such activity is charged directly to the DOS – ISN/CTR agreements these concepts, if approved, will fund. However, once the notice of funding opportunity (NOFO) is released, labor for such concept development intended to respond to the NOFO requirements should be charged as proposal costs. According to 2 CFR 200.460, proposal costs encompass the expenses incurred in preparing bids, proposals, or applications for potential federal and non-federal awards or projects. This includes the development of data necessary to support the bids or proposals. Generally, proposal costs, whether successful or unsuccessful, should be treated as indirect costs and allocated to all activities of the non-federal entity.
Cause
Ineffective time charging guidance was provided to program staff supporting the DOS – ISN/CTR’s NOFO response to clearly differentiate between time spent developing new concepts for a new funding opportunity versus time spent developing new concepts to be funded from active awarded agreements.
Effect
As a result, there is an incorrect reporting of payroll costs between direct and indirect categories for federally funded projects.
Questioned Costs
None.
Repeat Finding
No.
Recommendation
To address this issue, we recommend that management enhances its current policies and procedures. Specifically, there should be a focus on ensuring that effective time charging guidance is provided to program staff. Additionally, payroll and other expense allocations should be corrected to avoid any further discrepancy.