TLDR
Questioned costs are a normal part of federal grant audits - they are costs the auditor has flagged for additional scrutiny, not costs that have been determined unallowable. How an organization responds to questioned costs, and whether it self-reported issues proactively, significantly affects the outcome. Disallowed costs require repayment or appeal through the federal agency's administrative process.
Questioned vs. Disallowed: A Critical Distinction
The most important thing to understand when an auditor questions a cost: the finding is not final. A questioned cost is a cost the auditor has identified as potentially problematic - not a cost the federal agency has determined to be unallowable.
The organization has an opportunity to respond. That response can sometimes resolve a questioned cost before it becomes a disallowed cost, particularly when the issue is documentation rather than the nature of the expenditure itself.
The 2 CFR 200 Allowability Test
Every cost charged to a federal award must meet three criteria simultaneously.
Allowable. The cost must not be among the specifically unallowable categories listed in 2 CFR 200.420-200.475. It must be consistent with the organization’s accounting policies applied uniformly to all activities. For federally sponsored activities, the cost type must be permitted under the program’s applicable cost principles. An entertainment expense is unallowable regardless of how directly it relates to program activities.
Allocable. The cost must be allocable to the award - meaning it was incurred specifically to advance the work under the award, or it benefits both the award and other work and can be distributed in reasonable proportion to the benefits received. A cost that benefits only the award is 100% allocable to it. A cost that benefits multiple programs must be allocated based on relative benefit, with the allocation methodology documented.
Reasonable. A prudent person exercising due care would recognize the cost as necessary and would not have paid more for the same goods or services under similar circumstances. This is not a low bar: “necessary” means for the program, not for the organization generally. “Similar circumstances” means without the pressure of grant deadlines or personal relationships with vendors.
When Self-Reporting Makes Sense
The decision to self-report a potential compliance problem is consequential and context-dependent. Consider these factors:
Materiality. Small, isolated errors are unlikely to become material audit findings. A single misallocated transaction of $200 is not the same as a systemic pattern of charging unallowable costs. The more material the issue, the stronger the case for proactive disclosure.
Discoverability. If an auditor testing your major programs would almost certainly find the issue through standard sampling, self-reporting before fieldwork allows you to frame the narrative. Auditors who discover unreported issues treat them differently than disclosed issues.
The nature of the error. Inadvertent errors - miscoding, applying the wrong budget category, documentation gaps - are different from deliberate misrepresentation. Inadvertent errors, even material ones, are generally resolved through repayment and corrective action. Deliberate misrepresentation creates criminal exposure that self-reporting does not cure.
The mechanics of self-reporting: contact the grants management specialist assigned to the award and the program officer. Explain what happened, provide whatever documentation is available, and ask about available resolution options. Document your outreach in the grant file.
Responding Effectively to Questioned Costs During Audit
When a questioned cost appears in a draft audit finding, your response window is typically 30 days. Use it.
A strong response documents: why the cost meets the allowability, allocability, and reasonableness criteria; any documentation not previously provided to the auditor; the circumstances that led to the cost being questioned; whether the issue is isolated or systemic; and, if the cost is not defensible, an acknowledgment and a proposed corrective action plan.
Auditors are not trying to maximize questioned cost totals. A well-documented response that addresses the auditor’s concerns can result in questioned costs being removed from the finding or downgraded in severity. An unsupported response or no response at all leaves the finding unchanged.
After the Management Decision
The management decision from the federal agency sets the terms of resolution. For disallowed costs, it specifies the amount to be returned and the repayment timeline. For systemic findings, it establishes corrective action requirements and a schedule for demonstrating compliance.
Organizations that receive disallowance determinations have two paths: repayment or appeal. For genuinely unallowable costs, the most efficient path is usually negotiating a repayment plan with the grants management specialist. For costs where the organization believes the disallowance was incorrect or the documentation supports allowability, the administrative appeal process is available.
Appeal deadlines are strict and vary by agency. The management decision letter specifies the appeal procedure and timeline. Do not miss the appeal window while deciding whether to appeal.
Download the 2 CFR 200 Audit Prep Checklist to see the documentation areas that most commonly generate questioned costs, organized by audit compliance requirement.
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Get the 2 CFR 200 Audit Prep Checklist
A practical audit preparation checklist for federal grant recipients - organized by compliance area with notes on why auditors examine each item. Delivered by email.
- Questioned cost
- A cost that is questioned by the auditor as a result of an alleged violation of a provision of a law, regulation, contract, grant, cooperative agreement, or other agreement; a finding that, at the time of the audit, such cost is not supported by adequate documentation; or a finding that the expenditure of funds for the intended purpose is unnecessary or unreasonable.
DEFINITION
- Disallowed cost
- A questioned or other cost that the federal awarding agency or pass-through entity has determined to be unallowable in accordance with the applicable federal statutes, regulations, or terms and conditions of the federal award.
DEFINITION
- Management decision
- The evaluation by the federal awarding agency or pass-through entity of the audit findings and corrective action plan and the issuance of a written decision to the auditee as to what corrective action is necessary. Required within six months of audit submission per 2 CFR 200.521.
DEFINITION
Q&A
What costs are specifically listed as unallowable under 2 CFR 200?
2 CFR 200 explicitly lists categories of unallowable costs including: entertainment (200.438), alcoholic beverages (200.423), fundraising (200.442 - except under specific conditions), lobbying (200.450), fines and penalties (200.441), interest on borrowed capital (with narrow exceptions at 200.449), and contributions and donations (200.434). Each section should be checked against the specific cost in question.
Q&A
Can a disallowed cost be appealed after the management decision?
Yes. Each federal agency has an administrative appeal process for disallowance decisions. The appeal must generally be filed within a short window after the management decision is issued - time limits vary by agency and are specified in the management decision letter. If no administrative appeal procedure exists, the organization may seek judicial review. Appeals succeed when the organization has additional evidence supporting allowability that was not fully considered in the original decision.
Frequently asked