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.