Botanical Research Institute of Texas Inc

2023-001 Activities Allowed or Unallowed, Allowable Costs/ Cost Principles – Indirect Costs Cluster: Research and Development Cluster Grantor: National Science Foundation Award Name: Various Award Year: Various Award Numbers: Various CFDA Numbers: Various Criteria or specific requirement: Per 2 CFR section 200.303(a), a 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. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States. Condition: BRIT applies its predetermined approved facilities and administrative rate when charging indirect costs to federal awards rather than the 10% de minimis indirect cost rate as allowed under Uniform Guidance. During our testing of 55 indirect costs, 2 transactions did not calculate the correct indirect cost. Questioned costs: None Context: See Condition. Cause: The exception was caused by management human error in typing in the indirect percentage or formula. Effect: Incorrect allocation caused two transactions to which the incorrect rate was applied caused to over claim $645 of indirect cost. Recommendation: We recommend that the money is repaid or credited back to NSF: 1. Provide documentation supporting that it has repaid or otherwise credited the $645 of overcharged indirect costs for which it has agreed to reimburse NSF. 2. We recommend BRIT strengthen its existing internal controls over the review of grant expense to ensure indirect cost rates change and to take appropriate steps to avoid claiming unallowable indirect costs on NSF awards. Once NSF determines that the recommendations have been adequately addressed and the $645 costs have been resolved, this finding should be closed. Views of responsible officials: Management agrees with the finding. Corrective action plan: Management will strengthen existing internal control over the review of monthly accounting worksheet to ensure the formulas and percentage for indirect cost are accurate before invoicing federal entity. Implementation date: March 31, 2024. Responsible Person(s): Keri Barfield, CFO.