Audit 299886

2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster Grantor: Department of Health and Human Services and National Aeronautics and Space Administration Award Names: Biomedical Research and Research Training and Science Award Year: July 1, 2022 – June 30, 2023 Award Number: 5R01GM140457-03 and 80NSSC21K0753 Assistance Listing Numbers: 93.859 and 43.001 Pass-through entity: Not applicable Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, the College procedures include (amongst other items) obtaining a Commitment Form from the subrecipient, performing an initial risk assessment on all subrecipients, and updating that risk assessment based on the Controller Office’s judgement. The College also annually reviews the subrecipient's Uniform Guidance (“UG”) report and performs any necessary follow-up to issue a management decision, where applicable. Condition Through our testing of 4 subrecipients, we noted the following: • For all samples, we were unable to obtain sufficient evidence of the College’s annual subrecipient risk assessment. • For all samples, we were unable to obtain sufficient evidence of the College’s annual review of the audited financial statements and UG report, documentation of their review of the subrecipient’s audit report, and actions taken as a result of the findings in the report. Cause The College indicated subrecipient reviews, including the annual risk assessment and review of the UG report, were performed informally by the Principal Investigators and financial staff and not consistently documented. The College cites insufficient staffing needed for the formal documentation of the subrecipient risk assessment and monitoring procedures as the cause. Effect The lack of an annual review of subrecipient UG reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the UG. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs None identified. Recommendation We recommend the College reassess the design of its controls around subrecipient risk assessment and monitoring during the ongoing monitoring process. The College should formalize the documentation and review of its controls related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management’s Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings.

2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster Grantor: Department of Health and Human Services and National Aeronautics and Space Administration Award Names: Biomedical Research and Research Training and Science Award Year: July 1, 2022 – June 30, 2023 Award Number: 5R01GM140457-03 and 80NSSC21K0753 Assistance Listing Numbers: 93.859 and 43.001 Pass-through entity: Not applicable Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, the College procedures include (amongst other items) obtaining a Commitment Form from the subrecipient, performing an initial risk assessment on all subrecipients, and updating that risk assessment based on the Controller Office’s judgement. The College also annually reviews the subrecipient's Uniform Guidance (“UG”) report and performs any necessary follow-up to issue a management decision, where applicable. Condition Through our testing of 4 subrecipients, we noted the following: • For all samples, we were unable to obtain sufficient evidence of the College’s annual subrecipient risk assessment. • For all samples, we were unable to obtain sufficient evidence of the College’s annual review of the audited financial statements and UG report, documentation of their review of the subrecipient’s audit report, and actions taken as a result of the findings in the report. Cause The College indicated subrecipient reviews, including the annual risk assessment and review of the UG report, were performed informally by the Principal Investigators and financial staff and not consistently documented. The College cites insufficient staffing needed for the formal documentation of the subrecipient risk assessment and monitoring procedures as the cause. Effect The lack of an annual review of subrecipient UG reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the UG. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs None identified. Recommendation We recommend the College reassess the design of its controls around subrecipient risk assessment and monitoring during the ongoing monitoring process. The College should formalize the documentation and review of its controls related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management’s Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings.

2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster Grantor: Department of Health and Human Services and National Aeronautics and Space Administration Award Names: Biomedical Research and Research Training and Science Award Year: July 1, 2022 – June 30, 2023 Award Number: 5R01GM140457-03 and 80NSSC21K0753 Assistance Listing Numbers: 93.859 and 43.001 Pass-through entity: Not applicable Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, the College procedures include (amongst other items) obtaining a Commitment Form from the subrecipient, performing an initial risk assessment on all subrecipients, and updating that risk assessment based on the Controller Office’s judgement. The College also annually reviews the subrecipient's Uniform Guidance (“UG”) report and performs any necessary follow-up to issue a management decision, where applicable. Condition Through our testing of 4 subrecipients, we noted the following: • For all samples, we were unable to obtain sufficient evidence of the College’s annual subrecipient risk assessment. • For all samples, we were unable to obtain sufficient evidence of the College’s annual review of the audited financial statements and UG report, documentation of their review of the subrecipient’s audit report, and actions taken as a result of the findings in the report. Cause The College indicated subrecipient reviews, including the annual risk assessment and review of the UG report, were performed informally by the Principal Investigators and financial staff and not consistently documented. The College cites insufficient staffing needed for the formal documentation of the subrecipient risk assessment and monitoring procedures as the cause. Effect The lack of an annual review of subrecipient UG reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the UG. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs None identified. Recommendation We recommend the College reassess the design of its controls around subrecipient risk assessment and monitoring during the ongoing monitoring process. The College should formalize the documentation and review of its controls related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management’s Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings.

2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster Grantor: Department of Health and Human Services and National Aeronautics and Space Administration Award Names: Biomedical Research and Research Training and Science Award Year: July 1, 2022 – June 30, 2023 Award Number: 5R01GM140457-03 and 80NSSC21K0753 Assistance Listing Numbers: 93.859 and 43.001 Pass-through entity: Not applicable Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, the College procedures include (amongst other items) obtaining a Commitment Form from the subrecipient, performing an initial risk assessment on all subrecipients, and updating that risk assessment based on the Controller Office’s judgement. The College also annually reviews the subrecipient's Uniform Guidance (“UG”) report and performs any necessary follow-up to issue a management decision, where applicable. Condition Through our testing of 4 subrecipients, we noted the following: • For all samples, we were unable to obtain sufficient evidence of the College’s annual subrecipient risk assessment. • For all samples, we were unable to obtain sufficient evidence of the College’s annual review of the audited financial statements and UG report, documentation of their review of the subrecipient’s audit report, and actions taken as a result of the findings in the report. Cause The College indicated subrecipient reviews, including the annual risk assessment and review of the UG report, were performed informally by the Principal Investigators and financial staff and not consistently documented. The College cites insufficient staffing needed for the formal documentation of the subrecipient risk assessment and monitoring procedures as the cause. Effect The lack of an annual review of subrecipient UG reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the UG. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs None identified. Recommendation We recommend the College reassess the design of its controls around subrecipient risk assessment and monitoring during the ongoing monitoring process. The College should formalize the documentation and review of its controls related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management’s Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings.