Western Kentucky University

Finding 2021-001 ? Improper Claiming of Expenditures Information on the federal program: Governor?s Emergency Education Relief (GEER) Fund (CFDA Number: 84.425C) ? Education Stabilization Fund Criteria: Any cost allocable to a particular Federal award under the principles provided for in this part may not be charged to other Federal awards to overcome fund deficiencies, to avoid restrictions imposed by Federal statutes, regulations, or terms and conditions of the Federal awards, or for other reasons. However, this prohibition would not preclude the non-Federal entity from shifting costs that are allowable under two or more Federal awards in accordance with existing Federal statutes, regulations, or the terms and conditions of the Federal awards - 2CFR Part 200, Subpart E, ? 200.405 Allocable costs (c) Condition: During the audit, we noted instances in which the same expenditures were claimed for multiple federal programs. Questioned Cost: $169,443 (Known) Context: During our year-end testing of the Coronavirus Relief Fund (CRF) program it was determined that 5 CRF transactions (or invoices) that were claimed within the CRF program were also claimed within the GEER program. Management noted that the 5 transactions (totaling $169,443), were properly included and allowable under CRF, but shouldn't have also been included as a GEER related expenditure. Effect: The University did not comply with federal regulations and claimed the same expenses on two different Federal grant programs resulting in an unallowable cost for the GEER program. The granting agency has allowed the University to keep the funds and apply against future GEER expenses. At June 30, 2021, this amount is shown as unearned revenue on the statements of net position. Cause: The above condition was a result of significant turnover regarding the individuals involved with the program and the program being new to the University during current fiscal year. Additionally, the University did not utilize the grant index fund for the CRF program like they did for other grant programs. Repeat Finding: N/A Recommendation: We recommend that management look to implement an additional layer of review related to the expenditure process to further ensure that expenditures being claimed within this program aren't already being used within another program. Crowe also recommends that each expenditure be classified to a specific grant code or index and that grant claims be made based off of the activity in that code or index, thus greatly reducing the chance of claiming the same expense on multiple grants. Views of responsible officials and planned corrective actions: The University will implement an additional layer of review for any new revenue sources received from an outside entity to ensure all pass-through federal funding is identified and properly recorded using the established grant index fund procedures.