Audits of Federal Programs:

Reasons for Disparities Between Costs Questioned by Auditors and Amounts Agencies Disallow

AFMD-84-57: Published: Aug 8, 1984. Publicly Released: Aug 8, 1984.

Additional Materials:

Contact:

John J. Adair
(202) 275-5200
contact@gao.gov

 

Office of Public Affairs
(202) 512-4800
youngc1@gao.gov

Pursuant to a congressional request, GAO determined the reasons for disparities between the amount of contract and grant costs questioned by auditors and the amount eventually disallowed by program managers.

GAO generally found that proper procedures are used in reaching decisions to allow costs. However, GAO questioned procedures used in instances representing $163 million in allowed costs at six agencies. Program managers are partially responsible because they do not: (1) hold auditees accountable for correcting program deficiencies identified by audits; (2) adequately address issues raised by auditors; or (3) adequately justify decisions in writing. Questionable procedures identified by GAO include: (1) allowing questioned costs because of a proposed future audit; (2) allowing questioned costs because the auditee submitted a plan to correct identified deficiencies; (3) using special provisions to allow questioned costs; (4) allowing questioned costs on the basis of administrative actions; (5) allowing questioned costs on the grounds the auditee provided certification that costs were appropriately incurred; and (6) allowing questioned costs without providing, as required by Office of Management and Budget (OMB) guidelines, written justification as to why program officials disagreed with auditors. GAO also found: (1) some problems with audit quality, but it was unable to determine the extent of auditing errors; (2) that auditors do not always follow up on audit recommendations; and (3) that auditors do not always provide accurate and complete information to Congress regarding audit resolution.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: Please call 202/512-6100 for information.

    Recommendation: The Secretaries of Agriculture, Education, Health and Human Services, Labor, and Transportation, and the Administrator, EPA, should implement policies and procedures that: (1) ensure that administrative actions and special procedures or waivers, used to allow questioned costs, are used with discretion, in compliance with the law, and not used to merely expedite the resolution of the case without considering the issues raised by auditors; (2) where reaudit is required to make determinations, consider questioned costs unresolved until the reaudit can be completed and a final determination made; (3) eliminate the use of corrective action plans to allow costs when these costs represent the auditee's liability for past deficiencies; (4) consider questioned costs as being unresolved, rather than allowing them, when related to a deficiency requiring remedial action by the auditee, pending implementation if a corrective action plan addressing the deficiency; (5) limit auditee certifications to circumstances where the auditee could not be expected to have the necessary supporting documentation; and (6) ensure that program officials, in accordance with OMB Circular A-50, document in writing their decisions to allow costs.

    Agency Affected: Department of Agriculture

  2. Status: Closed - Implemented

    Comments: Please call 202/512-6100 for information.

    Recommendation: The Secretaries of Agriculture, Education, Health and Human Services, Labor, and Transportation, and the Administrator, EPA, should implement policies and procedures that: (1) ensure that administrative actions and special procedures or waivers, used to allow questioned costs, are used with discretion, in compliance with the law, and not used to merely expedite the resolution of the case without considering the issues raised by auditors; (2) where reaudit is required to make determinations, consider questioned costs unresolved until the reaudit can be completed and a final determination made; (3) eliminate the use of corrective action plans to allow costs when these costs represent the auditee's liability for past deficiencies; (4) consider questioned costs as being unresolved, rather than allowing them, when related to a deficiency requiring remedial action by the auditee, pending implementation if a corrective action plan addressing the deficiency; (5) limit auditee certifications to circumstances where the auditee could not be expected to have the necessary supporting documentation; and (6) ensure that program officials, in accordance with OMB Circular A-50, document in writing their decisions to allow costs.

    Agency Affected: Department of Education

  3. Status: Closed - Implemented

    Comments: Please call 202/512-6100 for information.

    Recommendation: The Secretaries of Agriculture, Education, Health and Human Services, Labor, and Transportation, and the Administrator, EPA, should implement policies and procedures that: (1) ensure that administrative actions and special procedures or waivers, used to allow questioned costs, are used with discretion, in compliance with the law, and not used to merely expedite the resolution of the case without considering the issues raised by auditors; (2) where reaudit is required to make determinations, consider questioned costs unresolved until the reaudit can be completed and a final determination made; (3) eliminate the use of corrective action plans to allow costs when these costs represent the auditee's liability for past deficiencies; (4) consider questioned costs as being unresolved, rather than allowing them, when related to a deficiency requiring remedial action by the auditee, pending implementation if a corrective action plan addressing the deficiency; (5) limit auditee certifications to circumstances where the auditee could not be expected to have the necessary supporting documentation; and (6) ensure that program officials, in accordance with OMB Circular A-50, document in writing their decisions to allow costs.

    Agency Affected: Department of Health and Human Services

  4. Status: Closed - Implemented

    Comments: Please call 202/512-6100 for information.

    Recommendation: The Secretaries of Agriculture, Education, Health and Human Services, Labor, and Transportation, and the Administrator, EPA, should implement policies and procedures that: (1) ensure that administrative actions and special procedures or waivers, used to allow questioned costs, are used with discretion, in compliance with the law, and not used to merely expedite the resolution of the case without considering the issues raised by auditors; (2) where reaudit is required to make determinations, consider questioned costs unresolved until the reaudit can be completed and a final determination made; (3) eliminate the use of corrective action plans to allow costs when these costs represent the auditee's liability for past deficiencies; (4) consider questioned costs as being unresolved, rather than allowing them, when related to a deficiency requiring remedial action by the auditee, pending implementation if a corrective action plan addressing the deficiency; (5) limit auditee certifications to circumstances where the auditee could not be expected to have the necessary supporting documentation; and (6) ensure that program officials, in accordance with OMB Circular A-50, document in writing their decisions to allow costs.

    Agency Affected: Department of Transportation

  5. Status: Closed - Implemented

    Comments: Please call 202/512-6100 for information.

    Recommendation: The Secretaries of Agriculture, Education, Health and Human Services, Labor, and Transportation, and the Administrator, EPA, should implement policies and procedures that: (1) ensure that administrative actions and special procedures or waivers, used to allow questioned costs, are used with discretion, in compliance with the law, and not used to merely expedite the resolution of the case without considering the issues raised by auditors; (2) where reaudit is required to make determinations, consider questioned costs unresolved until the reaudit can be completed and a final determination made; (3) eliminate the use of corrective action plans to allow costs when these costs represent the auditee's liability for past deficiencies; (4) consider questioned costs as being unresolved, rather than allowing them, when related to a deficiency requiring remedial action by the auditee, pending implementation if a corrective action plan addressing the deficiency; (5) limit auditee certifications to circumstances where the auditee could not be expected to have the necessary supporting documentation; and (6) ensure that program officials, in accordance with OMB Circular A-50, document in writing their decisions to allow costs.

    Agency Affected: Department of Labor

  6. Status: Closed - Implemented

    Comments: Please call 202/512-6100 for information.

    Recommendation: The Secretaries of Agriculture, Education, Health and Human Services, Labor, and Transportation, and the Administrator, EPA, should implement policies and procedures that: (1) ensure that administrative actions and special procedures or waivers, used to allow questioned costs, are used with discretion, in compliance with the law, and not used to merely expedite the resolution of the case without considering the issues raised by auditors; (2) where reaudit is required to make determinations, consider questioned costs unresolved until the reaudit can be completed and a final determination made; (3) eliminate the use of corrective action plans to allow costs when these costs represent the auditee's liability for past deficiencies; (4) consider questioned costs as being unresolved, rather than allowing them, when related to a deficiency requiring remedial action by the auditee, pending implementation if a corrective action plan addressing the deficiency; (5) limit auditee certifications to circumstances where the auditee could not be expected to have the necessary supporting documentation; and (6) ensure that program officials, in accordance with OMB Circular A-50, document in writing their decisions to allow costs.

    Agency Affected: Environmental Protection Agency

  7. Status: Closed - Implemented

    Comments: Please call 202/512-6100 for information.

    Recommendation: The head of each federal department and agency with an internal audit organization or inspector general should review that agency's audit resolution procedures and, where the aforementioned deficiencies exist, implement policies and procedures to correct them.

    Agency Affected: Heads of Federal Agencies

  8. Status: Closed - Not Implemented

    Comments: OMB believes that Circular A-50 currently requires agencies to do what GAO recommended; therefore, OMB does not believe that A-50 needs to be revised.

    Recommendation: The Director, OMB, should ensure that these recommendations are incorporated into OMB Circular A-50.

    Agency Affected: Executive Office of the President: Office of Management and Budget

  9. Status: Closed - Implemented

    Comments: Please call 202/512-6100 for information.

    Recommendation: The Secretaries of Agriculture, Education, Health and Human Services, Labor, and Transportation, and the Administrator, EPA, should ensure that disagreements between program officials and auditors over the resolution of questioned costs are considered by the audit followup official, as required by OMB, before a final decision is made on the case.

    Agency Affected: Department of Agriculture

  10. Status: Closed - Implemented

    Comments: Please call 202/512-6100 for information.

    Recommendation: The Secretaries of Agriculture, Education, Health and Human Services, Labor, and Transportation, and the Administrator, EPA, should ensure that disagreements between program officials and auditors over the resolution of questioned costs are considered by the audit followup official, as required by OMB, before a final decision is made on the case.

    Agency Affected: Department of Education

  11. Status: Closed - Implemented

    Comments: Please call 202/512-6100 for information.

    Recommendation: The Secretaries of Agriculture, Education, Health and Human Services, Labor, and Transportation, and the Administrator, EPA, should ensure that disagreements between program officials and auditors over the resolution of questioned costs are considered by the audit followup official, as required by OMB, before a final decision is made on the case.

    Agency Affected: Department of Health and Human Services

  12. Status: Closed - Implemented

    Comments: Please call 202/512-6100 for information.

    Recommendation: The Secretaries of Agriculture, Education, Health and Human Services, Labor, and Transportation, and the Administrator, EPA, should ensure that disagreements between program officials and auditors over the resolution of questioned costs are considered by the audit followup official, as required by OMB, before a final decision is made on the case.

    Agency Affected: Department of Transportation

  13. Status: Closed - Implemented

    Comments: Please call 202/512-6100 for information.

    Recommendation: The Secretaries of Agriculture, Education, Health and Human Services, Labor, and Transportation, and the Administrator, EPA, should ensure that disagreements between program officials and auditors over the resolution of questioned costs are considered by the audit followup official, as required by OMB, before a final decision is made on the case.

    Agency Affected: Department of Labor

  14. Status: Closed - Implemented

    Comments: Please call 202/512-6100 for information.

    Recommendation: The Secretaries of Agriculture, Education, Health and Human Services, Labor, and Transportation, and the Administrator, EPA, should ensure that disagreements between program officials and auditors over the resolution of questioned costs are considered by the audit followup official, as required by OMB, before a final decision is made on the case.

    Agency Affected: Environmental Protection Agency

  15. Status: Closed - Implemented

    Comments: Please call 202/512-6100 for information.

    Recommendation: The head of each federal department and agency with an internal audit organization or inspector general should determine whether a similar problem exists in that agency, and if it does, should take the same corrective action.

    Agency Affected: Heads of Federal Agencies

  16. Status: Closed - Implemented

    Comments: Please call 202/512-6100 for information.

    Recommendation: Inspectors general and heads of internal audit organizations should: (1) ensure that the requirements in the Comptroller General's audit resolution standard for following up on findings and recommendations are met; and (2) ensure compliance with OMB Circular A-50 requirements for reviewing program officials' responses to audit reports and reporting disagreements to the audit follow-up official.

    Agency Affected: Statutory Inspectors General

  17. Status: Closed - Not Implemented

    Comments: OMB does not agree since its definition of resolution, according to OMB, is in agreement with the definition of resolution as contained in P.L. 96-304.

    Recommendation: The Director, OMB, should revise the definition of audit resolution in OMB Circular A-50 to conform with the Comptroller General's standard.

    Agency Affected: Executive Office of the President: Office of Management and Budget

  18. Status: Closed - Not Implemented

    Comments: OMB believes that Circular A-50 currently requires agencies to do what GAO recommended; therefore, OMB does not believe that A-50 needs to be revised.

    Recommendation: In order to provide Congress with more complete and uniform audit resolution data, the Director, OMB, should revise OMB Circular A-50 to: (1) establish standard definitions of questioned cost and savings for reporting purposes; and (2) assign responsibility to agency audit followup officials for providing Inspectors General with the results of collection action taken on audit-related debt.

    Agency Affected: Executive Office of the President: Office of Management and Budget

  19. Status: Closed - Implemented

    Comments: Please call 202/512-6100 for information.

    Recommendation: In accordance with standard OMB definitions, Inspectors General should: (1) report all information requested by the Senate Committee on Appropriations contained in their report on the Supplemental Appropriations and Rescission Act of 1980; and (2) clearly state that reported disallowed cost is subject to reduction.

    Agency Affected: Statutory Inspectors General

 

Explore the full database of GAO's Open Recommendations »

Sep 20, 2016

Sep 6, 2016

Aug 19, 2016

Aug 12, 2016

Jul 29, 2016

Jul 28, 2016

Jul 13, 2016

Jul 11, 2016

Jun 13, 2016

Looking for more? Browse all our products here