Finding Text
2023-003 – Allowable Costs/Cost Principles
Federal program information:
Funding agency: U.S. Department of Health and Human Services
Title: Substance Use Disorder Residential Treatment for
Pregnant and Postpartum Women
Assistance listing number: 93.243
Award year: 9/30/2018 – 9/29/2023
Criteria: According to 2 CFR Part 200.403, to be allowable under federal awards, costs must be adequately documented, be necessary and reasonable for the performance of the federal award, and be allocable thereto under the principles in 2 CFR Part 200, Subpart E. Additionally, according to 2 CFR Part 200.430, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and comply with established accounting policies and practices of the entity.
Condition: Accurate and complete records to support disbursements were not maintained for the program. We specifically noted the following:
• SFRC is currently allocating payroll costs to the program based on budget estimates. There is not a process in place to compare the budget estimates to actual time and effort to ensure that budget estimates are accurate.
• For one month during fiscal year 2023, the amounts charged to the program were not supported by wages paid to the employee (used as the basis for the amount allocated to the program).
• For two of six non-payroll disbursements tested, the amount allocated to the program did not agree to the amount paid to the vendor.
• Indirect costs charged to the program were not allocated correctly based on SFRC’s approved indirect cost rate.
Context: 15 of 15 payroll transactions tested were allocated to the program based on budget estimates. Two of six non-payroll disbursements did not agree with source documentation.
Questioned Costs: $33,429
Cause: SFRC has not developed a process to compare the budget estimates to actual time and effort to ensure that budget estimates are accurate. There was not adequate review of reimbursement requests to ensure that payroll and non-payroll disbursements agree with source documentation. Indirect costs were not charged to the program using the approved indirect cost rate for fiscal year 2023.
Effect: SFRC may not be able to demonstrate that costs charged to federal programs are allowable.
Auditor’s Recommendation: SFRC should implement a process of comparing actual time and effort of employees to SFRC’s budget estimates at least bi-annually. Alternatively, SFRC could require employees to report their actual daily time on federal awards to ensure amounts charged are accurate and properly allocated. SFRC should implement a review process of reimbursement requests to ensure that disbursements agree with source documentation, and that indirect costs are charged to the program accurately.
Management’s Response: Management implemented a process to evaluate time spent each month. That allocation is used to classify actual salary paid to particular federal awards on a pay period basis.