Finding Text
Criteria or specific requirement: According to ? 2 CFR 200.303, Internal Controls, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. According to 2 CFR 200.1, Period of Performance is defined as the total estimated time interval between the start of an initial Federal award and the planned end date, which may include one or more funded portions, or budget periods. Condition: ? 93.958 o The Organization began allocating direct salaries, fringe, and indirect expenditures prior to the awards period of performance. The Organization allocated expenditures based on the paid date, rather than the incurred period. Total direct salaries, fringe and indirect expenditures allocated to the grant prior to the period of performance was approximately $50,701. ? 93.243 o The Organization began allocating direct salaries, fringe, and indirect expenditures prior to the awards period of performance. The Organization allocated expenditures based on the paid date, rather than the incurred period. Total direct salaries, fringe and indirect expenditures allocated to the grant prior to the period of performance was approximately $5,233. Questioned costs: None. Context: We noted the Organization is not in compliance with requirements related to the period of performance. Cause: The Organization allocated expenditures based on the paid date, rather than the incurred period. Effect: Noncompliance with federal regulations. Repeat Finding: No. Recommendation: We recommend the Organization update their method of allocating expenditures to federal awards based on the incurred date, rather than paid date. Views of responsible officials: Management concurs with the audit finding. As the previous process for grant salary, fringe, and indirect billings was based on salary paid date this resulted in expenses on certain grants being allocated prior to the period of performance. While this was at least in part offset by eligible grant expenses not being billed at the end of the grant period, it was not in compliance with 2 CFR 200.1 for period of performance. The CFO, supported by the Controller and Grants Manager, will immediately update the controls and grants billing processes to be based on incurred date rather than paid date.