Audit 295009

FY End
2019-12-31
Total Expended
$3.07M
Findings
22
Programs
6

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
375989 2019-001 Material Weakness - C
375990 2019-002 Material Weakness - M
375991 2019-003 Material Weakness - C
375992 2019-004 Material Weakness - I
375993 2019-005 Material Weakness - B
375994 2019-006 Material Weakness - L
375995 2019-007 Material Weakness Yes L
375996 2019-008 Material Weakness - L
375997 2019-009 Material Weakness - C
375998 2019-010 Material Weakness - N
375999 2019-011 Material Weakness - J
952431 2019-001 Material Weakness - C
952432 2019-002 Material Weakness - M
952433 2019-003 Material Weakness - C
952434 2019-004 Material Weakness - I
952435 2019-005 Material Weakness - B
952436 2019-006 Material Weakness - L
952437 2019-007 Material Weakness Yes L
952438 2019-008 Material Weakness - L
952439 2019-009 Material Weakness - C
952440 2019-010 Material Weakness - N
952441 2019-011 Material Weakness - J

Programs

ALN Program Spent Major Findings
47.050 Geosciences $1.45M Yes 1
47.080 Office of Cyberinfrastructure $80,192 Yes 1
47.083 Integrative Activities $28,517 Yes 1
47.079 Office of Internal Science and Engineering $13,688 Yes 1
47.070 Computer and Information Science Engineering $9,122 Yes 1
47.070 Computer and Information Science and Engineering $4,346 Yes 1

Contacts

Name Title Type
V7M9C3ZFCLS7 Jordan Read Auditee
3392215400 Robert Marquart Auditor
No contacts on file

Notes to SEFA

Title: Opinion Accounting Policies: Note 2. Summary of Significant Accounting Policies De Minimis Rate Used: N Rate Explanation: Used the rate of award. Disclaimer of Opinion
Title: Opinion Part 2 Accounting Policies: Note 2. Summary of Significant Accounting Policies De Minimis Rate Used: N Rate Explanation: Used the rate of award. We were engaged to audit the financial statements of Consortium of Universities for the Advancement of Hydrologic Science, Inc. as of and for the year ended December 31, 2019. We have issued our report thereon dated August 4, 2024. However, the scope of our audit of the financial statements was not sufficient to enable us to express an opinion because in 2022 the Organization hired an outsourced accounting provider to reconstruct all the accounting transactions for the year ended December 31, 2019, from bank statements and create a general ledger. The outsourced accounting provider’s systems and controls related to the services provided to the Organization were not evaluated as to their design and were not tested for their effectiveness. The transactions recorded by the outsourced accounting provider were the principal source of almost all transactions and journal entries recorded to create the financial statements for December 31, 2019. CUAHSI did not have internal controls and a functional accounting system for the year ended December 31, 2019. We could not review and reconcile approved invoices with the federal drawdowns which would have had a summary of the expenses and related indirect costs charged during the period of performance. It is possible for an entity to issue financial statements with an acceptable level of misstatements, with few or no controls placed in operation, but it would be highly unlikely if that outcome could be accomplished given the level of internal control deficiencies we observed, in combination with the unacceptable level of documentation deficiencies supporting the financial statement assertions and our auditing procedures. We identified several significant differences in account balances during our engagement that could not be reconciled, and we could not obtain assurance through extended audit procedures to resolve those differences and accordingly we did not express an opinion on such financial statements. The Schedule of Expenditures of Federal Awards is presented for the purposes of additional analysis and is not a required part of the basic financial statements. Because of the significance of the matter discussed above, it is inappropriate to and we do not express an opinion on the supplementary information referred to above. We are required to communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit, significant audit findings, and certain internal control-related matters that we identified during the audit. In our opinion, because of the significance of the matters discussed in Basis for Disclaimer of Opinion section of our report, CUAHSI did not comply, in all material respects, with the compliance requirements referred to above that could have a direct and material effect on the major programs of the National Science Foundation, Research and Development Cluster, AL No. 47.050, 47.070, 47.079, 47.080, and 47.083 for the year ended December 31, 2019.
Title: Basis for Opinion Accounting Policies: Note 2. Summary of Significant Accounting Policies De Minimis Rate Used: N Rate Explanation: Used the rate of award. We were engaged to audit the financial statements of Consortium of Universities for the Advancement of Hydrologic Science, Inc. as of and for the year ended December 31, 2019. We have issued our report thereon dated August 4, 2024. However, the scope of our audit of the financial statements was not sufficient to enable us to express an opinion because in 2022 the Organization hired an outsourced accounting provider to reconstruct all the accounting transactions for the year ended December 31, 2019, from bank statements and create a general ledger. The outsourced accounting provider’s systems and controls related to the services provided to the Organization were not evaluated as to their design and were not tested for their effectiveness. The transactions recorded by the outsourced accounting provider were the principal source of almost all transactions and journal entries recorded to create the financial statements for December 31, 2019.
Title: Responsibilities of Management for the Schedule Accounting Policies: Note 2. Summary of Significant Accounting Policies De Minimis Rate Used: N Rate Explanation: Used the rate of award. Management is responsible for the preparation and fair presentation of the schedule in accordance with accounting principles generally accepted in the United States of America and for the design, implementation, and maintenance of internal control relevant to the preparation and fair presentation of the schedule that is free from material misstatement, whether due to fraud or error.
Title: Auditor’s Responsibilities for the Audit of the Schedule Accounting Policies: Note 2. Summary of Significant Accounting Policies De Minimis Rate Used: N Rate Explanation: Used the rate of award. Our objectives are to obtain reasonable assurance about whether the schedule as a whole is free from material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our opinion. Reasonable assurance is a high level of assurance but is not absolute assurance and therefore is not a guarantee that an audit conducted in accordance with generally accepted auditing standards, Government Auditing Standards, and the Uniform Guidance will always detect a material misstatement when it exists. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control. Misstatements are considered material if there is a substantial likelihood that, individually or in aggregate, they would influence the judgment made by a reasonable user based on the schedule.
Title: Uniform Guidance 1 Accounting Policies: Note 2. Summary of Significant Accounting Policies De Minimis Rate Used: N Rate Explanation: Used the rate of award. In performing an audit in accordance with generally accepted auditing standards, Government Auditing Standards, and the Uniform Guidance, we:
Title: Uniform Guidance 2 Accounting Policies: Note 2. Summary of Significant Accounting Policies De Minimis Rate Used: N Rate Explanation: Used the rate of award. • Exercise professional judgment and maintain professional skepticism throughout the audit,
Title: Uniform Guidance 3 Accounting Policies: Note 2. Summary of Significant Accounting Policies De Minimis Rate Used: N Rate Explanation: Used the rate of award. • Identify and assess the risks of material misstatement of the schedule, whether due to fraud, or error, and design and perform audit procedures responsive to those risks. Such procedures include examining, on a test basis, evidence regarding the amounts and disclosures in the schedule.
Title: Uniform Guidance 4 Accounting Policies: Note 2. Summary of Significant Accounting Policies De Minimis Rate Used: N Rate Explanation: Used the rate of award. • Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of Consortium of Universities for the Advancement of Hydrologic Science, Inc. internal control. Accordingly, no such opinion is expressed.
Title: Uniform Guidance 5 Accounting Policies: Note 2. Summary of Significant Accounting Policies De Minimis Rate Used: N Rate Explanation: Used the rate of award. • Evaluate the appropriateness of accounting policies used and the reasonableness of significant accounting estimates made by management, as well as evaluate the overall presentation of the schedule.
Title: Uniform Guidance 6 Accounting Policies: Note 2. Summary of Significant Accounting Policies De Minimis Rate Used: N Rate Explanation: Used the rate of award. We are required to communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit, significant audit findings, and certain internal control-related matters that we identified during the audit.

Finding Details

Current management concurred with the conditions, criteria, causes, and recommendations cited by the auditors. Having to reconstruct the books and transitioning into a new Accounting System; Dynamics 365 was transitioned to Sage Intacct from 2019 forward in order to implement an auditable grant management system and an improved internal control system. In this process, the detailed reconciliations may have been abandoned in the older accounting system. The transition of new management in early 2023 has now implemented these internal control systems and monthly reconciliations from 2022 and forward in order to comply with 2 CFR 200 and NSF requirements.
CUAHSI's Federal Grant Management Policies and Procedures updated in February 2019 was not implemented and followed for calendar year 2019. In light of this finding, current management is reviewing the current Federal Grant Management Policies and Procedures along with Subrecipient Risk Assessment internally developed for financial and compliance monitoring in order to update and implement the regulatory required reporting and documentation moving forward.
Processes have now been implemented by new management to require Form SF-270 with source documentation backup for every drawdown submitted to the National Science Foundation.
Documentation in the present accounting system has not been maintained that verify contractors are not federally debarred, suspended, or excluded. A vendor onboarding process is currently being developed to address vendor verification and risk assessment.
Newly established retention and control of source documents has been implemented with new 2023 management within the accounting system providing source documentation for unlimited retention of source documentation to remedy the 4% inadequately documented transactions in this test pool.
Subsequent to year end of the audit period, CUAHSI replaced the contracted external finance team with two full-time CUAHSI employees and one part-time employee (these staff were hired in September and October of 2023). After this personnel change, CUAHSI was able to produce a SEFA (sent to the auditors via email December 4th, 2023).
2.Commonwealth of Massachusetts Attorney General’s Office Non-Profit Division – Registration andfilings of PC for the purposes of retaining non-profit status Certificate of Good Standing.
Prior source information coupled with flat drawdowns resulting in the lack of issued invoices were not available in reconstructing the books required in providing accurate allocation of real-time activities. Input of documentation was done directly from the organization's bank statements which does not reflect proper allocation. Future policy has been rectified to designate cost pools, dimensions and grant allocation with source documentation verified and included as backup in the new accounting system.
2019 Management retained the funds in lieu of redeposit resulting in the ACM$ drawdown being halted for the impacted award for 10 months before resuming draw downs. New 2023 Management has put internal controls in place with SF-270 submission for all drawdowns and source backup for all allowable expenses and procedures to ensure 2 CFR Part 200.305 compliance.
The Executive Committee has been informed by Management of all deficiencies for accountability. The reporting of all accounting and internal controls weaknesses is being reviewed and will be remedied with the approval of the Board and newly established Audit Committee.
Program income of $293,591 was entered into Sage and submitted to the auditor along with all other General Ledger details. Separately, CUAHSI reported program incomes of different (smaller) amounts to NSF that are likely reflective of actual incomes generated by the active awards. Potential mischaracterization in General Ledger detail may have resulted in overstating program income. The organization is working to implement processes that are 2 CFR Part 200.307 compliant and will be work with their cognizant agency to reconcile accurate program income relative to award draws.
Current management concurred with the conditions, criteria, causes, and recommendations cited by the auditors. Having to reconstruct the books and transitioning into a new Accounting System; Dynamics 365 was transitioned to Sage Intacct from 2019 forward in order to implement an auditable grant management system and an improved internal control system. In this process, the detailed reconciliations may have been abandoned in the older accounting system. The transition of new management in early 2023 has now implemented these internal control systems and monthly reconciliations from 2022 and forward in order to comply with 2 CFR 200 and NSF requirements.
CUAHSI's Federal Grant Management Policies and Procedures updated in February 2019 was not implemented and followed for calendar year 2019. In light of this finding, current management is reviewing the current Federal Grant Management Policies and Procedures along with Subrecipient Risk Assessment internally developed for financial and compliance monitoring in order to update and implement the regulatory required reporting and documentation moving forward.
Processes have now been implemented by new management to require Form SF-270 with source documentation backup for every drawdown submitted to the National Science Foundation.
Documentation in the present accounting system has not been maintained that verify contractors are not federally debarred, suspended, or excluded. A vendor onboarding process is currently being developed to address vendor verification and risk assessment.
Newly established retention and control of source documents has been implemented with new 2023 management within the accounting system providing source documentation for unlimited retention of source documentation to remedy the 4% inadequately documented transactions in this test pool.
Subsequent to year end of the audit period, CUAHSI replaced the contracted external finance team with two full-time CUAHSI employees and one part-time employee (these staff were hired in September and October of 2023). After this personnel change, CUAHSI was able to produce a SEFA (sent to the auditors via email December 4th, 2023).
2.Commonwealth of Massachusetts Attorney General’s Office Non-Profit Division – Registration andfilings of PC for the purposes of retaining non-profit status Certificate of Good Standing.
Prior source information coupled with flat drawdowns resulting in the lack of issued invoices were not available in reconstructing the books required in providing accurate allocation of real-time activities. Input of documentation was done directly from the organization's bank statements which does not reflect proper allocation. Future policy has been rectified to designate cost pools, dimensions and grant allocation with source documentation verified and included as backup in the new accounting system.
2019 Management retained the funds in lieu of redeposit resulting in the ACM$ drawdown being halted for the impacted award for 10 months before resuming draw downs. New 2023 Management has put internal controls in place with SF-270 submission for all drawdowns and source backup for all allowable expenses and procedures to ensure 2 CFR Part 200.305 compliance.
The Executive Committee has been informed by Management of all deficiencies for accountability. The reporting of all accounting and internal controls weaknesses is being reviewed and will be remedied with the approval of the Board and newly established Audit Committee.
Program income of $293,591 was entered into Sage and submitted to the auditor along with all other General Ledger details. Separately, CUAHSI reported program incomes of different (smaller) amounts to NSF that are likely reflective of actual incomes generated by the active awards. Potential mischaracterization in General Ledger detail may have resulted in overstating program income. The organization is working to implement processes that are 2 CFR Part 200.307 compliant and will be work with their cognizant agency to reconcile accurate program income relative to award draws.