Questioned vs. Unallowable Costs: There's a Difference

What the Regulations Say

The Uniform Guidance Sec. 2 CFR 200.84 states:

More properly known as an Improper Payment, an Unallowable Cost is any payment that meets one or more of the following conditions:

• should not have been made,

• was made in an incorrect amount under applicable requirements,

• was made for ineligible goods, recipients, or services,

• was made for goods or services not received, or

• was made without adequate supporting documentation.

A Questioned Cost is not considered an Improper Payment until the transaction has been completely reviewed and is confirmed to be improper.

Uniform Guidance Sec. 2 CFR 200.410 states that Unallowable Costs must be refunded unless a Federal statute or regulation directs otherwise.

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