Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Criteria or Specific Requirement – Procurement and Suspension and Debarment
In accordance with 2 CFR Section 200.320, a non-federal entity must have and use documented procurement procedures consistent with the standards of Sections 200.317 - 200.320. These standards include a micro-purchase threshold of $10,000 and policies for formal procurement and non competitive procurement. Additionally, in accordance with 2 CFR Section 180.220, when a non-federal entity
enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition – The Institute's micro-purchase threshold of $25,000 included in the policy is in excess of
2 CFR Section 200.320, and the Institute is not eligible for the increase to the micro-purchase threshold. Formal procurement and non competitive procurement policies have been documented; however, formalized documentation supporting the Institute is in compliance with policies did not exist. Additionally, there was no suspension and debarment check completed prior to purchases made with federal funds.
Questioned Costs – Total questioned costs of $45,000 were identified and represents value of equipment purchased for which the procurement process could not be supported in line with the Institute's policy and Uniform Guidance. Context – One purchase of $45,000 out of a total of three purchases totaling $152,986 subject to procurement requirements in 2023 was selected for testing. The Institute could not provide documentation supporting their purchase adhered to policies for formal procurement or non competitive procurement. Furthermore, a check of the vendor's suspension and debarment status prior to the purchase was not completed. The sample was not intended to be, and was not, a statistically valid sample.
Effect – Federal funds could be used to make an unauthorized purchase including paying an entity that is suspended or debarred.
Cause – The Institute's procurement policies are not in accordance with the Uniform Guidance, nor are there controls in place to ensure policies are followed, and lastly, there are no controls to ensure suspension and debarment checks are performed on vendors receiving federal funds.
Identification as a Repeat Finding, if applicable – Not a repeat finding. Recommendation – Policies and procedures should be modified to ensure that procurement policies and suspension and debarment checks on vendors are performed prior to making purchases with federal funds and are in alignment with the Uniform Guidance requirements.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Criteria or Specific Requirement – Procurement and Suspension and Debarment
In accordance with 2 CFR Section 200.320, a non-federal entity must have and use documented procurement procedures consistent with the standards of Sections 200.317 - 200.320. These standards include a micro-purchase threshold of $10,000 and policies for formal procurement and non competitive procurement. Additionally, in accordance with 2 CFR Section 180.220, when a non-federal entity
enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition – The Institute's micro-purchase threshold of $25,000 included in the policy is in excess of
2 CFR Section 200.320, and the Institute is not eligible for the increase to the micro-purchase threshold. Formal procurement and non competitive procurement policies have been documented; however, formalized documentation supporting the Institute is in compliance with policies did not exist. Additionally, there was no suspension and debarment check completed prior to purchases made with federal funds.
Questioned Costs – Total questioned costs of $45,000 were identified and represents value of equipment purchased for which the procurement process could not be supported in line with the Institute's policy and Uniform Guidance. Context – One purchase of $45,000 out of a total of three purchases totaling $152,986 subject to procurement requirements in 2023 was selected for testing. The Institute could not provide documentation supporting their purchase adhered to policies for formal procurement or non competitive procurement. Furthermore, a check of the vendor's suspension and debarment status prior to the purchase was not completed. The sample was not intended to be, and was not, a statistically valid sample.
Effect – Federal funds could be used to make an unauthorized purchase including paying an entity that is suspended or debarred.
Cause – The Institute's procurement policies are not in accordance with the Uniform Guidance, nor are there controls in place to ensure policies are followed, and lastly, there are no controls to ensure suspension and debarment checks are performed on vendors receiving federal funds.
Identification as a Repeat Finding, if applicable – Not a repeat finding. Recommendation – Policies and procedures should be modified to ensure that procurement policies and suspension and debarment checks on vendors are performed prior to making purchases with federal funds and are in alignment with the Uniform Guidance requirements.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Criteria or Specific Requirement – Procurement and Suspension and Debarment
In accordance with 2 CFR Section 200.320, a non-federal entity must have and use documented procurement procedures consistent with the standards of Sections 200.317 - 200.320. These standards include a micro-purchase threshold of $10,000 and policies for formal procurement and non competitive procurement. Additionally, in accordance with 2 CFR Section 180.220, when a non-federal entity
enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition – The Institute's micro-purchase threshold of $25,000 included in the policy is in excess of
2 CFR Section 200.320, and the Institute is not eligible for the increase to the micro-purchase threshold. Formal procurement and non competitive procurement policies have been documented; however, formalized documentation supporting the Institute is in compliance with policies did not exist. Additionally, there was no suspension and debarment check completed prior to purchases made with federal funds.
Questioned Costs – Total questioned costs of $45,000 were identified and represents value of equipment purchased for which the procurement process could not be supported in line with the Institute's policy and Uniform Guidance. Context – One purchase of $45,000 out of a total of three purchases totaling $152,986 subject to procurement requirements in 2023 was selected for testing. The Institute could not provide documentation supporting their purchase adhered to policies for formal procurement or non competitive procurement. Furthermore, a check of the vendor's suspension and debarment status prior to the purchase was not completed. The sample was not intended to be, and was not, a statistically valid sample.
Effect – Federal funds could be used to make an unauthorized purchase including paying an entity that is suspended or debarred.
Cause – The Institute's procurement policies are not in accordance with the Uniform Guidance, nor are there controls in place to ensure policies are followed, and lastly, there are no controls to ensure suspension and debarment checks are performed on vendors receiving federal funds.
Identification as a Repeat Finding, if applicable – Not a repeat finding. Recommendation – Policies and procedures should be modified to ensure that procurement policies and suspension and debarment checks on vendors are performed prior to making purchases with federal funds and are in alignment with the Uniform Guidance requirements.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Criteria or Specific Requirement – Procurement and Suspension and Debarment
In accordance with 2 CFR Section 200.320, a non-federal entity must have and use documented procurement procedures consistent with the standards of Sections 200.317 - 200.320. These standards include a micro-purchase threshold of $10,000 and policies for formal procurement and non competitive procurement. Additionally, in accordance with 2 CFR Section 180.220, when a non-federal entity
enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition – The Institute's micro-purchase threshold of $25,000 included in the policy is in excess of
2 CFR Section 200.320, and the Institute is not eligible for the increase to the micro-purchase threshold. Formal procurement and non competitive procurement policies have been documented; however, formalized documentation supporting the Institute is in compliance with policies did not exist. Additionally, there was no suspension and debarment check completed prior to purchases made with federal funds.
Questioned Costs – Total questioned costs of $45,000 were identified and represents value of equipment purchased for which the procurement process could not be supported in line with the Institute's policy and Uniform Guidance. Context – One purchase of $45,000 out of a total of three purchases totaling $152,986 subject to procurement requirements in 2023 was selected for testing. The Institute could not provide documentation supporting their purchase adhered to policies for formal procurement or non competitive procurement. Furthermore, a check of the vendor's suspension and debarment status prior to the purchase was not completed. The sample was not intended to be, and was not, a statistically valid sample.
Effect – Federal funds could be used to make an unauthorized purchase including paying an entity that is suspended or debarred.
Cause – The Institute's procurement policies are not in accordance with the Uniform Guidance, nor are there controls in place to ensure policies are followed, and lastly, there are no controls to ensure suspension and debarment checks are performed on vendors receiving federal funds.
Identification as a Repeat Finding, if applicable – Not a repeat finding. Recommendation – Policies and procedures should be modified to ensure that procurement policies and suspension and debarment checks on vendors are performed prior to making purchases with federal funds and are in alignment with the Uniform Guidance requirements.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Criteria or Specific Requirement – Procurement and Suspension and Debarment
In accordance with 2 CFR Section 200.320, a non-federal entity must have and use documented procurement procedures consistent with the standards of Sections 200.317 - 200.320. These standards include a micro-purchase threshold of $10,000 and policies for formal procurement and non competitive procurement. Additionally, in accordance with 2 CFR Section 180.220, when a non-federal entity
enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition – The Institute's micro-purchase threshold of $25,000 included in the policy is in excess of
2 CFR Section 200.320, and the Institute is not eligible for the increase to the micro-purchase threshold. Formal procurement and non competitive procurement policies have been documented; however, formalized documentation supporting the Institute is in compliance with policies did not exist. Additionally, there was no suspension and debarment check completed prior to purchases made with federal funds.
Questioned Costs – Total questioned costs of $45,000 were identified and represents value of equipment purchased for which the procurement process could not be supported in line with the Institute's policy and Uniform Guidance. Context – One purchase of $45,000 out of a total of three purchases totaling $152,986 subject to procurement requirements in 2023 was selected for testing. The Institute could not provide documentation supporting their purchase adhered to policies for formal procurement or non competitive procurement. Furthermore, a check of the vendor's suspension and debarment status prior to the purchase was not completed. The sample was not intended to be, and was not, a statistically valid sample.
Effect – Federal funds could be used to make an unauthorized purchase including paying an entity that is suspended or debarred.
Cause – The Institute's procurement policies are not in accordance with the Uniform Guidance, nor are there controls in place to ensure policies are followed, and lastly, there are no controls to ensure suspension and debarment checks are performed on vendors receiving federal funds.
Identification as a Repeat Finding, if applicable – Not a repeat finding. Recommendation – Policies and procedures should be modified to ensure that procurement policies and suspension and debarment checks on vendors are performed prior to making purchases with federal funds and are in alignment with the Uniform Guidance requirements.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Criteria or Specific Requirement – Procurement and Suspension and Debarment
In accordance with 2 CFR Section 200.320, a non-federal entity must have and use documented procurement procedures consistent with the standards of Sections 200.317 - 200.320. These standards include a micro-purchase threshold of $10,000 and policies for formal procurement and non competitive procurement. Additionally, in accordance with 2 CFR Section 180.220, when a non-federal entity
enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition – The Institute's micro-purchase threshold of $25,000 included in the policy is in excess of
2 CFR Section 200.320, and the Institute is not eligible for the increase to the micro-purchase threshold. Formal procurement and non competitive procurement policies have been documented; however, formalized documentation supporting the Institute is in compliance with policies did not exist. Additionally, there was no suspension and debarment check completed prior to purchases made with federal funds.
Questioned Costs – Total questioned costs of $45,000 were identified and represents value of equipment purchased for which the procurement process could not be supported in line with the Institute's policy and Uniform Guidance. Context – One purchase of $45,000 out of a total of three purchases totaling $152,986 subject to procurement requirements in 2023 was selected for testing. The Institute could not provide documentation supporting their purchase adhered to policies for formal procurement or non competitive procurement. Furthermore, a check of the vendor's suspension and debarment status prior to the purchase was not completed. The sample was not intended to be, and was not, a statistically valid sample.
Effect – Federal funds could be used to make an unauthorized purchase including paying an entity that is suspended or debarred.
Cause – The Institute's procurement policies are not in accordance with the Uniform Guidance, nor are there controls in place to ensure policies are followed, and lastly, there are no controls to ensure suspension and debarment checks are performed on vendors receiving federal funds.
Identification as a Repeat Finding, if applicable – Not a repeat finding. Recommendation – Policies and procedures should be modified to ensure that procurement policies and suspension and debarment checks on vendors are performed prior to making purchases with federal funds and are in alignment with the Uniform Guidance requirements.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Criteria or Specific Requirement – Procurement and Suspension and Debarment
In accordance with 2 CFR Section 200.320, a non-federal entity must have and use documented procurement procedures consistent with the standards of Sections 200.317 - 200.320. These standards include a micro-purchase threshold of $10,000 and policies for formal procurement and non competitive procurement. Additionally, in accordance with 2 CFR Section 180.220, when a non-federal entity
enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition – The Institute's micro-purchase threshold of $25,000 included in the policy is in excess of
2 CFR Section 200.320, and the Institute is not eligible for the increase to the micro-purchase threshold. Formal procurement and non competitive procurement policies have been documented; however, formalized documentation supporting the Institute is in compliance with policies did not exist. Additionally, there was no suspension and debarment check completed prior to purchases made with federal funds.
Questioned Costs – Total questioned costs of $45,000 were identified and represents value of equipment purchased for which the procurement process could not be supported in line with the Institute's policy and Uniform Guidance. Context – One purchase of $45,000 out of a total of three purchases totaling $152,986 subject to procurement requirements in 2023 was selected for testing. The Institute could not provide documentation supporting their purchase adhered to policies for formal procurement or non competitive procurement. Furthermore, a check of the vendor's suspension and debarment status prior to the purchase was not completed. The sample was not intended to be, and was not, a statistically valid sample.
Effect – Federal funds could be used to make an unauthorized purchase including paying an entity that is suspended or debarred.
Cause – The Institute's procurement policies are not in accordance with the Uniform Guidance, nor are there controls in place to ensure policies are followed, and lastly, there are no controls to ensure suspension and debarment checks are performed on vendors receiving federal funds.
Identification as a Repeat Finding, if applicable – Not a repeat finding. Recommendation – Policies and procedures should be modified to ensure that procurement policies and suspension and debarment checks on vendors are performed prior to making purchases with federal funds and are in alignment with the Uniform Guidance requirements.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Criteria or Specific Requirement – Procurement and Suspension and Debarment
In accordance with 2 CFR Section 200.320, a non-federal entity must have and use documented procurement procedures consistent with the standards of Sections 200.317 - 200.320. These standards include a micro-purchase threshold of $10,000 and policies for formal procurement and non competitive procurement. Additionally, in accordance with 2 CFR Section 180.220, when a non-federal entity
enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition – The Institute's micro-purchase threshold of $25,000 included in the policy is in excess of
2 CFR Section 200.320, and the Institute is not eligible for the increase to the micro-purchase threshold. Formal procurement and non competitive procurement policies have been documented; however, formalized documentation supporting the Institute is in compliance with policies did not exist. Additionally, there was no suspension and debarment check completed prior to purchases made with federal funds.
Questioned Costs – Total questioned costs of $45,000 were identified and represents value of equipment purchased for which the procurement process could not be supported in line with the Institute's policy and Uniform Guidance. Context – One purchase of $45,000 out of a total of three purchases totaling $152,986 subject to procurement requirements in 2023 was selected for testing. The Institute could not provide documentation supporting their purchase adhered to policies for formal procurement or non competitive procurement. Furthermore, a check of the vendor's suspension and debarment status prior to the purchase was not completed. The sample was not intended to be, and was not, a statistically valid sample.
Effect – Federal funds could be used to make an unauthorized purchase including paying an entity that is suspended or debarred.
Cause – The Institute's procurement policies are not in accordance with the Uniform Guidance, nor are there controls in place to ensure policies are followed, and lastly, there are no controls to ensure suspension and debarment checks are performed on vendors receiving federal funds.
Identification as a Repeat Finding, if applicable – Not a repeat finding. Recommendation – Policies and procedures should be modified to ensure that procurement policies and suspension and debarment checks on vendors are performed prior to making purchases with federal funds and are in alignment with the Uniform Guidance requirements.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Criteria or Specific Requirement – Procurement and Suspension and Debarment
In accordance with 2 CFR Section 200.320, a non-federal entity must have and use documented procurement procedures consistent with the standards of Sections 200.317 - 200.320. These standards include a micro-purchase threshold of $10,000 and policies for formal procurement and non competitive procurement. Additionally, in accordance with 2 CFR Section 180.220, when a non-federal entity
enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition – The Institute's micro-purchase threshold of $25,000 included in the policy is in excess of
2 CFR Section 200.320, and the Institute is not eligible for the increase to the micro-purchase threshold. Formal procurement and non competitive procurement policies have been documented; however, formalized documentation supporting the Institute is in compliance with policies did not exist. Additionally, there was no suspension and debarment check completed prior to purchases made with federal funds.
Questioned Costs – Total questioned costs of $45,000 were identified and represents value of equipment purchased for which the procurement process could not be supported in line with the Institute's policy and Uniform Guidance. Context – One purchase of $45,000 out of a total of three purchases totaling $152,986 subject to procurement requirements in 2023 was selected for testing. The Institute could not provide documentation supporting their purchase adhered to policies for formal procurement or non competitive procurement. Furthermore, a check of the vendor's suspension and debarment status prior to the purchase was not completed. The sample was not intended to be, and was not, a statistically valid sample.
Effect – Federal funds could be used to make an unauthorized purchase including paying an entity that is suspended or debarred.
Cause – The Institute's procurement policies are not in accordance with the Uniform Guidance, nor are there controls in place to ensure policies are followed, and lastly, there are no controls to ensure suspension and debarment checks are performed on vendors receiving federal funds.
Identification as a Repeat Finding, if applicable – Not a repeat finding. Recommendation – Policies and procedures should be modified to ensure that procurement policies and suspension and debarment checks on vendors are performed prior to making purchases with federal funds and are in alignment with the Uniform Guidance requirements.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Criteria or Specific Requirement – Procurement and Suspension and Debarment
In accordance with 2 CFR Section 200.320, a non-federal entity must have and use documented procurement procedures consistent with the standards of Sections 200.317 - 200.320. These standards include a micro-purchase threshold of $10,000 and policies for formal procurement and non competitive procurement. Additionally, in accordance with 2 CFR Section 180.220, when a non-federal entity
enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition – The Institute's micro-purchase threshold of $25,000 included in the policy is in excess of
2 CFR Section 200.320, and the Institute is not eligible for the increase to the micro-purchase threshold. Formal procurement and non competitive procurement policies have been documented; however, formalized documentation supporting the Institute is in compliance with policies did not exist. Additionally, there was no suspension and debarment check completed prior to purchases made with federal funds.
Questioned Costs – Total questioned costs of $45,000 were identified and represents value of equipment purchased for which the procurement process could not be supported in line with the Institute's policy and Uniform Guidance. Context – One purchase of $45,000 out of a total of three purchases totaling $152,986 subject to procurement requirements in 2023 was selected for testing. The Institute could not provide documentation supporting their purchase adhered to policies for formal procurement or non competitive procurement. Furthermore, a check of the vendor's suspension and debarment status prior to the purchase was not completed. The sample was not intended to be, and was not, a statistically valid sample.
Effect – Federal funds could be used to make an unauthorized purchase including paying an entity that is suspended or debarred.
Cause – The Institute's procurement policies are not in accordance with the Uniform Guidance, nor are there controls in place to ensure policies are followed, and lastly, there are no controls to ensure suspension and debarment checks are performed on vendors receiving federal funds.
Identification as a Repeat Finding, if applicable – Not a repeat finding. Recommendation – Policies and procedures should be modified to ensure that procurement policies and suspension and debarment checks on vendors are performed prior to making purchases with federal funds and are in alignment with the Uniform Guidance requirements.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Criteria or Specific Requirement – Procurement and Suspension and Debarment
In accordance with 2 CFR Section 200.320, a non-federal entity must have and use documented procurement procedures consistent with the standards of Sections 200.317 - 200.320. These standards include a micro-purchase threshold of $10,000 and policies for formal procurement and non competitive procurement. Additionally, in accordance with 2 CFR Section 180.220, when a non-federal entity
enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition – The Institute's micro-purchase threshold of $25,000 included in the policy is in excess of
2 CFR Section 200.320, and the Institute is not eligible for the increase to the micro-purchase threshold. Formal procurement and non competitive procurement policies have been documented; however, formalized documentation supporting the Institute is in compliance with policies did not exist. Additionally, there was no suspension and debarment check completed prior to purchases made with federal funds.
Questioned Costs – Total questioned costs of $45,000 were identified and represents value of equipment purchased for which the procurement process could not be supported in line with the Institute's policy and Uniform Guidance. Context – One purchase of $45,000 out of a total of three purchases totaling $152,986 subject to procurement requirements in 2023 was selected for testing. The Institute could not provide documentation supporting their purchase adhered to policies for formal procurement or non competitive procurement. Furthermore, a check of the vendor's suspension and debarment status prior to the purchase was not completed. The sample was not intended to be, and was not, a statistically valid sample.
Effect – Federal funds could be used to make an unauthorized purchase including paying an entity that is suspended or debarred.
Cause – The Institute's procurement policies are not in accordance with the Uniform Guidance, nor are there controls in place to ensure policies are followed, and lastly, there are no controls to ensure suspension and debarment checks are performed on vendors receiving federal funds.
Identification as a Repeat Finding, if applicable – Not a repeat finding. Recommendation – Policies and procedures should be modified to ensure that procurement policies and suspension and debarment checks on vendors are performed prior to making purchases with federal funds and are in alignment with the Uniform Guidance requirements.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Equipment and Real Property Management
In accordance with 2 CFR Section 200.313, a non-federal entity must manage equipment that was procured through the use of federal funds by: maintaining property records, performing a physical inventory once every two years, controls must be implemented to safeguard against loss, and adequate maintenance procedures developed. Condition – During testing of equipment, a complete listing of all property and equipment purchased with federal funds with required information per 2 CFR 200.313(d)(1) was not maintained. A physical inventory of property and equipment was not completed in the past two years.
Questioned Costs – None noted.
Context – The Institute purchased two pieces of equipment totaling $142,986 during 2023. Both pieces of equipment were included in a detail listing of all equipment the Institute maintains. However, during further discussions with the Institute, they were unable to provide a complete listing of equipment purchased through the use of federal funds with all required information.
Effect – Equipment purchased through the use of federal funds is not maintained or disposed of in accordance with the Uniform Guidance.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the equipment policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Equipment and Real Property Management
In accordance with 2 CFR Section 200.313, a non-federal entity must manage equipment that was procured through the use of federal funds by: maintaining property records, performing a physical inventory once every two years, controls must be implemented to safeguard against loss, and adequate maintenance procedures developed. Condition – During testing of equipment, a complete listing of all property and equipment purchased with federal funds with required information per 2 CFR 200.313(d)(1) was not maintained. A physical inventory of property and equipment was not completed in the past two years.
Questioned Costs – None noted.
Context – The Institute purchased two pieces of equipment totaling $142,986 during 2023. Both pieces of equipment were included in a detail listing of all equipment the Institute maintains. However, during further discussions with the Institute, they were unable to provide a complete listing of equipment purchased through the use of federal funds with all required information.
Effect – Equipment purchased through the use of federal funds is not maintained or disposed of in accordance with the Uniform Guidance.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the equipment policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Equipment and Real Property Management
In accordance with 2 CFR Section 200.313, a non-federal entity must manage equipment that was procured through the use of federal funds by: maintaining property records, performing a physical inventory once every two years, controls must be implemented to safeguard against loss, and adequate maintenance procedures developed. Condition – During testing of equipment, a complete listing of all property and equipment purchased with federal funds with required information per 2 CFR 200.313(d)(1) was not maintained. A physical inventory of property and equipment was not completed in the past two years.
Questioned Costs – None noted.
Context – The Institute purchased two pieces of equipment totaling $142,986 during 2023. Both pieces of equipment were included in a detail listing of all equipment the Institute maintains. However, during further discussions with the Institute, they were unable to provide a complete listing of equipment purchased through the use of federal funds with all required information.
Effect – Equipment purchased through the use of federal funds is not maintained or disposed of in accordance with the Uniform Guidance.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the equipment policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Equipment and Real Property Management
In accordance with 2 CFR Section 200.313, a non-federal entity must manage equipment that was procured through the use of federal funds by: maintaining property records, performing a physical inventory once every two years, controls must be implemented to safeguard against loss, and adequate maintenance procedures developed. Condition – During testing of equipment, a complete listing of all property and equipment purchased with federal funds with required information per 2 CFR 200.313(d)(1) was not maintained. A physical inventory of property and equipment was not completed in the past two years.
Questioned Costs – None noted.
Context – The Institute purchased two pieces of equipment totaling $142,986 during 2023. Both pieces of equipment were included in a detail listing of all equipment the Institute maintains. However, during further discussions with the Institute, they were unable to provide a complete listing of equipment purchased through the use of federal funds with all required information.
Effect – Equipment purchased through the use of federal funds is not maintained or disposed of in accordance with the Uniform Guidance.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the equipment policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Equipment and Real Property Management
In accordance with 2 CFR Section 200.313, a non-federal entity must manage equipment that was procured through the use of federal funds by: maintaining property records, performing a physical inventory once every two years, controls must be implemented to safeguard against loss, and adequate maintenance procedures developed. Condition – During testing of equipment, a complete listing of all property and equipment purchased with federal funds with required information per 2 CFR 200.313(d)(1) was not maintained. A physical inventory of property and equipment was not completed in the past two years.
Questioned Costs – None noted.
Context – The Institute purchased two pieces of equipment totaling $142,986 during 2023. Both pieces of equipment were included in a detail listing of all equipment the Institute maintains. However, during further discussions with the Institute, they were unable to provide a complete listing of equipment purchased through the use of federal funds with all required information.
Effect – Equipment purchased through the use of federal funds is not maintained or disposed of in accordance with the Uniform Guidance.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the equipment policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Equipment and Real Property Management
In accordance with 2 CFR Section 200.313, a non-federal entity must manage equipment that was procured through the use of federal funds by: maintaining property records, performing a physical inventory once every two years, controls must be implemented to safeguard against loss, and adequate maintenance procedures developed. Condition – During testing of equipment, a complete listing of all property and equipment purchased with federal funds with required information per 2 CFR 200.313(d)(1) was not maintained. A physical inventory of property and equipment was not completed in the past two years.
Questioned Costs – None noted.
Context – The Institute purchased two pieces of equipment totaling $142,986 during 2023. Both pieces of equipment were included in a detail listing of all equipment the Institute maintains. However, during further discussions with the Institute, they were unable to provide a complete listing of equipment purchased through the use of federal funds with all required information.
Effect – Equipment purchased through the use of federal funds is not maintained or disposed of in accordance with the Uniform Guidance.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the equipment policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Equipment and Real Property Management
In accordance with 2 CFR Section 200.313, a non-federal entity must manage equipment that was procured through the use of federal funds by: maintaining property records, performing a physical inventory once every two years, controls must be implemented to safeguard against loss, and adequate maintenance procedures developed. Condition – During testing of equipment, a complete listing of all property and equipment purchased with federal funds with required information per 2 CFR 200.313(d)(1) was not maintained. A physical inventory of property and equipment was not completed in the past two years.
Questioned Costs – None noted.
Context – The Institute purchased two pieces of equipment totaling $142,986 during 2023. Both pieces of equipment were included in a detail listing of all equipment the Institute maintains. However, during further discussions with the Institute, they were unable to provide a complete listing of equipment purchased through the use of federal funds with all required information.
Effect – Equipment purchased through the use of federal funds is not maintained or disposed of in accordance with the Uniform Guidance.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the equipment policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Equipment and Real Property Management
In accordance with 2 CFR Section 200.313, a non-federal entity must manage equipment that was procured through the use of federal funds by: maintaining property records, performing a physical inventory once every two years, controls must be implemented to safeguard against loss, and adequate maintenance procedures developed. Condition – During testing of equipment, a complete listing of all property and equipment purchased with federal funds with required information per 2 CFR 200.313(d)(1) was not maintained. A physical inventory of property and equipment was not completed in the past two years.
Questioned Costs – None noted.
Context – The Institute purchased two pieces of equipment totaling $142,986 during 2023. Both pieces of equipment were included in a detail listing of all equipment the Institute maintains. However, during further discussions with the Institute, they were unable to provide a complete listing of equipment purchased through the use of federal funds with all required information.
Effect – Equipment purchased through the use of federal funds is not maintained or disposed of in accordance with the Uniform Guidance.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the equipment policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Equipment and Real Property Management
In accordance with 2 CFR Section 200.313, a non-federal entity must manage equipment that was procured through the use of federal funds by: maintaining property records, performing a physical inventory once every two years, controls must be implemented to safeguard against loss, and adequate maintenance procedures developed. Condition – During testing of equipment, a complete listing of all property and equipment purchased with federal funds with required information per 2 CFR 200.313(d)(1) was not maintained. A physical inventory of property and equipment was not completed in the past two years.
Questioned Costs – None noted.
Context – The Institute purchased two pieces of equipment totaling $142,986 during 2023. Both pieces of equipment were included in a detail listing of all equipment the Institute maintains. However, during further discussions with the Institute, they were unable to provide a complete listing of equipment purchased through the use of federal funds with all required information.
Effect – Equipment purchased through the use of federal funds is not maintained or disposed of in accordance with the Uniform Guidance.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the equipment policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Equipment and Real Property Management
In accordance with 2 CFR Section 200.313, a non-federal entity must manage equipment that was procured through the use of federal funds by: maintaining property records, performing a physical inventory once every two years, controls must be implemented to safeguard against loss, and adequate maintenance procedures developed. Condition – During testing of equipment, a complete listing of all property and equipment purchased with federal funds with required information per 2 CFR 200.313(d)(1) was not maintained. A physical inventory of property and equipment was not completed in the past two years.
Questioned Costs – None noted.
Context – The Institute purchased two pieces of equipment totaling $142,986 during 2023. Both pieces of equipment were included in a detail listing of all equipment the Institute maintains. However, during further discussions with the Institute, they were unable to provide a complete listing of equipment purchased through the use of federal funds with all required information.
Effect – Equipment purchased through the use of federal funds is not maintained or disposed of in accordance with the Uniform Guidance.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the equipment policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Equipment and Real Property Management
In accordance with 2 CFR Section 200.313, a non-federal entity must manage equipment that was procured through the use of federal funds by: maintaining property records, performing a physical inventory once every two years, controls must be implemented to safeguard against loss, and adequate maintenance procedures developed. Condition – During testing of equipment, a complete listing of all property and equipment purchased with federal funds with required information per 2 CFR 200.313(d)(1) was not maintained. A physical inventory of property and equipment was not completed in the past two years.
Questioned Costs – None noted.
Context – The Institute purchased two pieces of equipment totaling $142,986 during 2023. Both pieces of equipment were included in a detail listing of all equipment the Institute maintains. However, during further discussions with the Institute, they were unable to provide a complete listing of equipment purchased through the use of federal funds with all required information.
Effect – Equipment purchased through the use of federal funds is not maintained or disposed of in accordance with the Uniform Guidance.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the equipment policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Special Test - Key Personnel
In accordance with 2 CFR Section 200.308(c)(2) and (3), for non-construction federal awards, recipients must request prior approvals from federal awarding agencies for the change in a key person specified in the application or the federal award or the disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
Condition – During testing, we did not identify any requests for changes or disengagement of key personnel.
Questioned Costs – None noted.
Context – During testing of key personnel, three individuals were included in the project budget for grant 2020-68012-31934 (ALN # 10.310) and only two were noted to have participated in the project during the year. The Institute provided support for the disengagement of one key personnel that was reported to the grantor; however, the reporting occurred after the fact rather than receiving prior approval as required by the Uniform Guidance. Effect – The disengagement of a named key person may have occurred without prior approval.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the key personnel policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Special Test - Key Personnel
In accordance with 2 CFR Section 200.308(c)(2) and (3), for non-construction federal awards, recipients must request prior approvals from federal awarding agencies for the change in a key person specified in the application or the federal award or the disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
Condition – During testing, we did not identify any requests for changes or disengagement of key personnel.
Questioned Costs – None noted.
Context – During testing of key personnel, three individuals were included in the project budget for grant 2020-68012-31934 (ALN # 10.310) and only two were noted to have participated in the project during the year. The Institute provided support for the disengagement of one key personnel that was reported to the grantor; however, the reporting occurred after the fact rather than receiving prior approval as required by the Uniform Guidance. Effect – The disengagement of a named key person may have occurred without prior approval.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the key personnel policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Special Test - Key Personnel
In accordance with 2 CFR Section 200.308(c)(2) and (3), for non-construction federal awards, recipients must request prior approvals from federal awarding agencies for the change in a key person specified in the application or the federal award or the disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
Condition – During testing, we did not identify any requests for changes or disengagement of key personnel.
Questioned Costs – None noted.
Context – During testing of key personnel, three individuals were included in the project budget for grant 2020-68012-31934 (ALN # 10.310) and only two were noted to have participated in the project during the year. The Institute provided support for the disengagement of one key personnel that was reported to the grantor; however, the reporting occurred after the fact rather than receiving prior approval as required by the Uniform Guidance. Effect – The disengagement of a named key person may have occurred without prior approval.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the key personnel policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Special Test - Key Personnel
In accordance with 2 CFR Section 200.308(c)(2) and (3), for non-construction federal awards, recipients must request prior approvals from federal awarding agencies for the change in a key person specified in the application or the federal award or the disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
Condition – During testing, we did not identify any requests for changes or disengagement of key personnel.
Questioned Costs – None noted.
Context – During testing of key personnel, three individuals were included in the project budget for grant 2020-68012-31934 (ALN # 10.310) and only two were noted to have participated in the project during the year. The Institute provided support for the disengagement of one key personnel that was reported to the grantor; however, the reporting occurred after the fact rather than receiving prior approval as required by the Uniform Guidance. Effect – The disengagement of a named key person may have occurred without prior approval.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the key personnel policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Special Test - Key Personnel
In accordance with 2 CFR Section 200.308(c)(2) and (3), for non-construction federal awards, recipients must request prior approvals from federal awarding agencies for the change in a key person specified in the application or the federal award or the disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
Condition – During testing, we did not identify any requests for changes or disengagement of key personnel.
Questioned Costs – None noted.
Context – During testing of key personnel, three individuals were included in the project budget for grant 2020-68012-31934 (ALN # 10.310) and only two were noted to have participated in the project during the year. The Institute provided support for the disengagement of one key personnel that was reported to the grantor; however, the reporting occurred after the fact rather than receiving prior approval as required by the Uniform Guidance. Effect – The disengagement of a named key person may have occurred without prior approval.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the key personnel policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Special Test - Key Personnel
In accordance with 2 CFR Section 200.308(c)(2) and (3), for non-construction federal awards, recipients must request prior approvals from federal awarding agencies for the change in a key person specified in the application or the federal award or the disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
Condition – During testing, we did not identify any requests for changes or disengagement of key personnel.
Questioned Costs – None noted.
Context – During testing of key personnel, three individuals were included in the project budget for grant 2020-68012-31934 (ALN # 10.310) and only two were noted to have participated in the project during the year. The Institute provided support for the disengagement of one key personnel that was reported to the grantor; however, the reporting occurred after the fact rather than receiving prior approval as required by the Uniform Guidance. Effect – The disengagement of a named key person may have occurred without prior approval.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the key personnel policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Special Test - Key Personnel
In accordance with 2 CFR Section 200.308(c)(2) and (3), for non-construction federal awards, recipients must request prior approvals from federal awarding agencies for the change in a key person specified in the application or the federal award or the disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
Condition – During testing, we did not identify any requests for changes or disengagement of key personnel.
Questioned Costs – None noted.
Context – During testing of key personnel, three individuals were included in the project budget for grant 2020-68012-31934 (ALN # 10.310) and only two were noted to have participated in the project during the year. The Institute provided support for the disengagement of one key personnel that was reported to the grantor; however, the reporting occurred after the fact rather than receiving prior approval as required by the Uniform Guidance. Effect – The disengagement of a named key person may have occurred without prior approval.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the key personnel policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Special Test - Key Personnel
In accordance with 2 CFR Section 200.308(c)(2) and (3), for non-construction federal awards, recipients must request prior approvals from federal awarding agencies for the change in a key person specified in the application or the federal award or the disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
Condition – During testing, we did not identify any requests for changes or disengagement of key personnel.
Questioned Costs – None noted.
Context – During testing of key personnel, three individuals were included in the project budget for grant 2020-68012-31934 (ALN # 10.310) and only two were noted to have participated in the project during the year. The Institute provided support for the disengagement of one key personnel that was reported to the grantor; however, the reporting occurred after the fact rather than receiving prior approval as required by the Uniform Guidance. Effect – The disengagement of a named key person may have occurred without prior approval.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the key personnel policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Special Test - Key Personnel
In accordance with 2 CFR Section 200.308(c)(2) and (3), for non-construction federal awards, recipients must request prior approvals from federal awarding agencies for the change in a key person specified in the application or the federal award or the disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
Condition – During testing, we did not identify any requests for changes or disengagement of key personnel.
Questioned Costs – None noted.
Context – During testing of key personnel, three individuals were included in the project budget for grant 2020-68012-31934 (ALN # 10.310) and only two were noted to have participated in the project during the year. The Institute provided support for the disengagement of one key personnel that was reported to the grantor; however, the reporting occurred after the fact rather than receiving prior approval as required by the Uniform Guidance. Effect – The disengagement of a named key person may have occurred without prior approval.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the key personnel policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Special Test - Key Personnel
In accordance with 2 CFR Section 200.308(c)(2) and (3), for non-construction federal awards, recipients must request prior approvals from federal awarding agencies for the change in a key person specified in the application or the federal award or the disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
Condition – During testing, we did not identify any requests for changes or disengagement of key personnel.
Questioned Costs – None noted.
Context – During testing of key personnel, three individuals were included in the project budget for grant 2020-68012-31934 (ALN # 10.310) and only two were noted to have participated in the project during the year. The Institute provided support for the disengagement of one key personnel that was reported to the grantor; however, the reporting occurred after the fact rather than receiving prior approval as required by the Uniform Guidance. Effect – The disengagement of a named key person may have occurred without prior approval.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the key personnel policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Special Test - Key Personnel
In accordance with 2 CFR Section 200.308(c)(2) and (3), for non-construction federal awards, recipients must request prior approvals from federal awarding agencies for the change in a key person specified in the application or the federal award or the disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
Condition – During testing, we did not identify any requests for changes or disengagement of key personnel.
Questioned Costs – None noted.
Context – During testing of key personnel, three individuals were included in the project budget for grant 2020-68012-31934 (ALN # 10.310) and only two were noted to have participated in the project during the year. The Institute provided support for the disengagement of one key personnel that was reported to the grantor; however, the reporting occurred after the fact rather than receiving prior approval as required by the Uniform Guidance. Effect – The disengagement of a named key person may have occurred without prior approval.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the key personnel policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Criteria or Specific Requirement – Procurement and Suspension and Debarment
In accordance with 2 CFR Section 200.320, a non-federal entity must have and use documented procurement procedures consistent with the standards of Sections 200.317 - 200.320. These standards include a micro-purchase threshold of $10,000 and policies for formal procurement and non competitive procurement. Additionally, in accordance with 2 CFR Section 180.220, when a non-federal entity
enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition – The Institute's micro-purchase threshold of $25,000 included in the policy is in excess of
2 CFR Section 200.320, and the Institute is not eligible for the increase to the micro-purchase threshold. Formal procurement and non competitive procurement policies have been documented; however, formalized documentation supporting the Institute is in compliance with policies did not exist. Additionally, there was no suspension and debarment check completed prior to purchases made with federal funds.
Questioned Costs – Total questioned costs of $45,000 were identified and represents value of equipment purchased for which the procurement process could not be supported in line with the Institute's policy and Uniform Guidance. Context – One purchase of $45,000 out of a total of three purchases totaling $152,986 subject to procurement requirements in 2023 was selected for testing. The Institute could not provide documentation supporting their purchase adhered to policies for formal procurement or non competitive procurement. Furthermore, a check of the vendor's suspension and debarment status prior to the purchase was not completed. The sample was not intended to be, and was not, a statistically valid sample.
Effect – Federal funds could be used to make an unauthorized purchase including paying an entity that is suspended or debarred.
Cause – The Institute's procurement policies are not in accordance with the Uniform Guidance, nor are there controls in place to ensure policies are followed, and lastly, there are no controls to ensure suspension and debarment checks are performed on vendors receiving federal funds.
Identification as a Repeat Finding, if applicable – Not a repeat finding. Recommendation – Policies and procedures should be modified to ensure that procurement policies and suspension and debarment checks on vendors are performed prior to making purchases with federal funds and are in alignment with the Uniform Guidance requirements.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Criteria or Specific Requirement – Procurement and Suspension and Debarment
In accordance with 2 CFR Section 200.320, a non-federal entity must have and use documented procurement procedures consistent with the standards of Sections 200.317 - 200.320. These standards include a micro-purchase threshold of $10,000 and policies for formal procurement and non competitive procurement. Additionally, in accordance with 2 CFR Section 180.220, when a non-federal entity
enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition – The Institute's micro-purchase threshold of $25,000 included in the policy is in excess of
2 CFR Section 200.320, and the Institute is not eligible for the increase to the micro-purchase threshold. Formal procurement and non competitive procurement policies have been documented; however, formalized documentation supporting the Institute is in compliance with policies did not exist. Additionally, there was no suspension and debarment check completed prior to purchases made with federal funds.
Questioned Costs – Total questioned costs of $45,000 were identified and represents value of equipment purchased for which the procurement process could not be supported in line with the Institute's policy and Uniform Guidance. Context – One purchase of $45,000 out of a total of three purchases totaling $152,986 subject to procurement requirements in 2023 was selected for testing. The Institute could not provide documentation supporting their purchase adhered to policies for formal procurement or non competitive procurement. Furthermore, a check of the vendor's suspension and debarment status prior to the purchase was not completed. The sample was not intended to be, and was not, a statistically valid sample.
Effect – Federal funds could be used to make an unauthorized purchase including paying an entity that is suspended or debarred.
Cause – The Institute's procurement policies are not in accordance with the Uniform Guidance, nor are there controls in place to ensure policies are followed, and lastly, there are no controls to ensure suspension and debarment checks are performed on vendors receiving federal funds.
Identification as a Repeat Finding, if applicable – Not a repeat finding. Recommendation – Policies and procedures should be modified to ensure that procurement policies and suspension and debarment checks on vendors are performed prior to making purchases with federal funds and are in alignment with the Uniform Guidance requirements.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Criteria or Specific Requirement – Procurement and Suspension and Debarment
In accordance with 2 CFR Section 200.320, a non-federal entity must have and use documented procurement procedures consistent with the standards of Sections 200.317 - 200.320. These standards include a micro-purchase threshold of $10,000 and policies for formal procurement and non competitive procurement. Additionally, in accordance with 2 CFR Section 180.220, when a non-federal entity
enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition – The Institute's micro-purchase threshold of $25,000 included in the policy is in excess of
2 CFR Section 200.320, and the Institute is not eligible for the increase to the micro-purchase threshold. Formal procurement and non competitive procurement policies have been documented; however, formalized documentation supporting the Institute is in compliance with policies did not exist. Additionally, there was no suspension and debarment check completed prior to purchases made with federal funds.
Questioned Costs – Total questioned costs of $45,000 were identified and represents value of equipment purchased for which the procurement process could not be supported in line with the Institute's policy and Uniform Guidance. Context – One purchase of $45,000 out of a total of three purchases totaling $152,986 subject to procurement requirements in 2023 was selected for testing. The Institute could not provide documentation supporting their purchase adhered to policies for formal procurement or non competitive procurement. Furthermore, a check of the vendor's suspension and debarment status prior to the purchase was not completed. The sample was not intended to be, and was not, a statistically valid sample.
Effect – Federal funds could be used to make an unauthorized purchase including paying an entity that is suspended or debarred.
Cause – The Institute's procurement policies are not in accordance with the Uniform Guidance, nor are there controls in place to ensure policies are followed, and lastly, there are no controls to ensure suspension and debarment checks are performed on vendors receiving federal funds.
Identification as a Repeat Finding, if applicable – Not a repeat finding. Recommendation – Policies and procedures should be modified to ensure that procurement policies and suspension and debarment checks on vendors are performed prior to making purchases with federal funds and are in alignment with the Uniform Guidance requirements.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Criteria or Specific Requirement – Procurement and Suspension and Debarment
In accordance with 2 CFR Section 200.320, a non-federal entity must have and use documented procurement procedures consistent with the standards of Sections 200.317 - 200.320. These standards include a micro-purchase threshold of $10,000 and policies for formal procurement and non competitive procurement. Additionally, in accordance with 2 CFR Section 180.220, when a non-federal entity
enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition – The Institute's micro-purchase threshold of $25,000 included in the policy is in excess of
2 CFR Section 200.320, and the Institute is not eligible for the increase to the micro-purchase threshold. Formal procurement and non competitive procurement policies have been documented; however, formalized documentation supporting the Institute is in compliance with policies did not exist. Additionally, there was no suspension and debarment check completed prior to purchases made with federal funds.
Questioned Costs – Total questioned costs of $45,000 were identified and represents value of equipment purchased for which the procurement process could not be supported in line with the Institute's policy and Uniform Guidance. Context – One purchase of $45,000 out of a total of three purchases totaling $152,986 subject to procurement requirements in 2023 was selected for testing. The Institute could not provide documentation supporting their purchase adhered to policies for formal procurement or non competitive procurement. Furthermore, a check of the vendor's suspension and debarment status prior to the purchase was not completed. The sample was not intended to be, and was not, a statistically valid sample.
Effect – Federal funds could be used to make an unauthorized purchase including paying an entity that is suspended or debarred.
Cause – The Institute's procurement policies are not in accordance with the Uniform Guidance, nor are there controls in place to ensure policies are followed, and lastly, there are no controls to ensure suspension and debarment checks are performed on vendors receiving federal funds.
Identification as a Repeat Finding, if applicable – Not a repeat finding. Recommendation – Policies and procedures should be modified to ensure that procurement policies and suspension and debarment checks on vendors are performed prior to making purchases with federal funds and are in alignment with the Uniform Guidance requirements.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Criteria or Specific Requirement – Procurement and Suspension and Debarment
In accordance with 2 CFR Section 200.320, a non-federal entity must have and use documented procurement procedures consistent with the standards of Sections 200.317 - 200.320. These standards include a micro-purchase threshold of $10,000 and policies for formal procurement and non competitive procurement. Additionally, in accordance with 2 CFR Section 180.220, when a non-federal entity
enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition – The Institute's micro-purchase threshold of $25,000 included in the policy is in excess of
2 CFR Section 200.320, and the Institute is not eligible for the increase to the micro-purchase threshold. Formal procurement and non competitive procurement policies have been documented; however, formalized documentation supporting the Institute is in compliance with policies did not exist. Additionally, there was no suspension and debarment check completed prior to purchases made with federal funds.
Questioned Costs – Total questioned costs of $45,000 were identified and represents value of equipment purchased for which the procurement process could not be supported in line with the Institute's policy and Uniform Guidance. Context – One purchase of $45,000 out of a total of three purchases totaling $152,986 subject to procurement requirements in 2023 was selected for testing. The Institute could not provide documentation supporting their purchase adhered to policies for formal procurement or non competitive procurement. Furthermore, a check of the vendor's suspension and debarment status prior to the purchase was not completed. The sample was not intended to be, and was not, a statistically valid sample.
Effect – Federal funds could be used to make an unauthorized purchase including paying an entity that is suspended or debarred.
Cause – The Institute's procurement policies are not in accordance with the Uniform Guidance, nor are there controls in place to ensure policies are followed, and lastly, there are no controls to ensure suspension and debarment checks are performed on vendors receiving federal funds.
Identification as a Repeat Finding, if applicable – Not a repeat finding. Recommendation – Policies and procedures should be modified to ensure that procurement policies and suspension and debarment checks on vendors are performed prior to making purchases with federal funds and are in alignment with the Uniform Guidance requirements.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Criteria or Specific Requirement – Procurement and Suspension and Debarment
In accordance with 2 CFR Section 200.320, a non-federal entity must have and use documented procurement procedures consistent with the standards of Sections 200.317 - 200.320. These standards include a micro-purchase threshold of $10,000 and policies for formal procurement and non competitive procurement. Additionally, in accordance with 2 CFR Section 180.220, when a non-federal entity
enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition – The Institute's micro-purchase threshold of $25,000 included in the policy is in excess of
2 CFR Section 200.320, and the Institute is not eligible for the increase to the micro-purchase threshold. Formal procurement and non competitive procurement policies have been documented; however, formalized documentation supporting the Institute is in compliance with policies did not exist. Additionally, there was no suspension and debarment check completed prior to purchases made with federal funds.
Questioned Costs – Total questioned costs of $45,000 were identified and represents value of equipment purchased for which the procurement process could not be supported in line with the Institute's policy and Uniform Guidance. Context – One purchase of $45,000 out of a total of three purchases totaling $152,986 subject to procurement requirements in 2023 was selected for testing. The Institute could not provide documentation supporting their purchase adhered to policies for formal procurement or non competitive procurement. Furthermore, a check of the vendor's suspension and debarment status prior to the purchase was not completed. The sample was not intended to be, and was not, a statistically valid sample.
Effect – Federal funds could be used to make an unauthorized purchase including paying an entity that is suspended or debarred.
Cause – The Institute's procurement policies are not in accordance with the Uniform Guidance, nor are there controls in place to ensure policies are followed, and lastly, there are no controls to ensure suspension and debarment checks are performed on vendors receiving federal funds.
Identification as a Repeat Finding, if applicable – Not a repeat finding. Recommendation – Policies and procedures should be modified to ensure that procurement policies and suspension and debarment checks on vendors are performed prior to making purchases with federal funds and are in alignment with the Uniform Guidance requirements.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Criteria or Specific Requirement – Procurement and Suspension and Debarment
In accordance with 2 CFR Section 200.320, a non-federal entity must have and use documented procurement procedures consistent with the standards of Sections 200.317 - 200.320. These standards include a micro-purchase threshold of $10,000 and policies for formal procurement and non competitive procurement. Additionally, in accordance with 2 CFR Section 180.220, when a non-federal entity
enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition – The Institute's micro-purchase threshold of $25,000 included in the policy is in excess of
2 CFR Section 200.320, and the Institute is not eligible for the increase to the micro-purchase threshold. Formal procurement and non competitive procurement policies have been documented; however, formalized documentation supporting the Institute is in compliance with policies did not exist. Additionally, there was no suspension and debarment check completed prior to purchases made with federal funds.
Questioned Costs – Total questioned costs of $45,000 were identified and represents value of equipment purchased for which the procurement process could not be supported in line with the Institute's policy and Uniform Guidance. Context – One purchase of $45,000 out of a total of three purchases totaling $152,986 subject to procurement requirements in 2023 was selected for testing. The Institute could not provide documentation supporting their purchase adhered to policies for formal procurement or non competitive procurement. Furthermore, a check of the vendor's suspension and debarment status prior to the purchase was not completed. The sample was not intended to be, and was not, a statistically valid sample.
Effect – Federal funds could be used to make an unauthorized purchase including paying an entity that is suspended or debarred.
Cause – The Institute's procurement policies are not in accordance with the Uniform Guidance, nor are there controls in place to ensure policies are followed, and lastly, there are no controls to ensure suspension and debarment checks are performed on vendors receiving federal funds.
Identification as a Repeat Finding, if applicable – Not a repeat finding. Recommendation – Policies and procedures should be modified to ensure that procurement policies and suspension and debarment checks on vendors are performed prior to making purchases with federal funds and are in alignment with the Uniform Guidance requirements.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Criteria or Specific Requirement – Procurement and Suspension and Debarment
In accordance with 2 CFR Section 200.320, a non-federal entity must have and use documented procurement procedures consistent with the standards of Sections 200.317 - 200.320. These standards include a micro-purchase threshold of $10,000 and policies for formal procurement and non competitive procurement. Additionally, in accordance with 2 CFR Section 180.220, when a non-federal entity
enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition – The Institute's micro-purchase threshold of $25,000 included in the policy is in excess of
2 CFR Section 200.320, and the Institute is not eligible for the increase to the micro-purchase threshold. Formal procurement and non competitive procurement policies have been documented; however, formalized documentation supporting the Institute is in compliance with policies did not exist. Additionally, there was no suspension and debarment check completed prior to purchases made with federal funds.
Questioned Costs – Total questioned costs of $45,000 were identified and represents value of equipment purchased for which the procurement process could not be supported in line with the Institute's policy and Uniform Guidance. Context – One purchase of $45,000 out of a total of three purchases totaling $152,986 subject to procurement requirements in 2023 was selected for testing. The Institute could not provide documentation supporting their purchase adhered to policies for formal procurement or non competitive procurement. Furthermore, a check of the vendor's suspension and debarment status prior to the purchase was not completed. The sample was not intended to be, and was not, a statistically valid sample.
Effect – Federal funds could be used to make an unauthorized purchase including paying an entity that is suspended or debarred.
Cause – The Institute's procurement policies are not in accordance with the Uniform Guidance, nor are there controls in place to ensure policies are followed, and lastly, there are no controls to ensure suspension and debarment checks are performed on vendors receiving federal funds.
Identification as a Repeat Finding, if applicable – Not a repeat finding. Recommendation – Policies and procedures should be modified to ensure that procurement policies and suspension and debarment checks on vendors are performed prior to making purchases with federal funds and are in alignment with the Uniform Guidance requirements.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Criteria or Specific Requirement – Procurement and Suspension and Debarment
In accordance with 2 CFR Section 200.320, a non-federal entity must have and use documented procurement procedures consistent with the standards of Sections 200.317 - 200.320. These standards include a micro-purchase threshold of $10,000 and policies for formal procurement and non competitive procurement. Additionally, in accordance with 2 CFR Section 180.220, when a non-federal entity
enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition – The Institute's micro-purchase threshold of $25,000 included in the policy is in excess of
2 CFR Section 200.320, and the Institute is not eligible for the increase to the micro-purchase threshold. Formal procurement and non competitive procurement policies have been documented; however, formalized documentation supporting the Institute is in compliance with policies did not exist. Additionally, there was no suspension and debarment check completed prior to purchases made with federal funds.
Questioned Costs – Total questioned costs of $45,000 were identified and represents value of equipment purchased for which the procurement process could not be supported in line with the Institute's policy and Uniform Guidance. Context – One purchase of $45,000 out of a total of three purchases totaling $152,986 subject to procurement requirements in 2023 was selected for testing. The Institute could not provide documentation supporting their purchase adhered to policies for formal procurement or non competitive procurement. Furthermore, a check of the vendor's suspension and debarment status prior to the purchase was not completed. The sample was not intended to be, and was not, a statistically valid sample.
Effect – Federal funds could be used to make an unauthorized purchase including paying an entity that is suspended or debarred.
Cause – The Institute's procurement policies are not in accordance with the Uniform Guidance, nor are there controls in place to ensure policies are followed, and lastly, there are no controls to ensure suspension and debarment checks are performed on vendors receiving federal funds.
Identification as a Repeat Finding, if applicable – Not a repeat finding. Recommendation – Policies and procedures should be modified to ensure that procurement policies and suspension and debarment checks on vendors are performed prior to making purchases with federal funds and are in alignment with the Uniform Guidance requirements.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Criteria or Specific Requirement – Procurement and Suspension and Debarment
In accordance with 2 CFR Section 200.320, a non-federal entity must have and use documented procurement procedures consistent with the standards of Sections 200.317 - 200.320. These standards include a micro-purchase threshold of $10,000 and policies for formal procurement and non competitive procurement. Additionally, in accordance with 2 CFR Section 180.220, when a non-federal entity
enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition – The Institute's micro-purchase threshold of $25,000 included in the policy is in excess of
2 CFR Section 200.320, and the Institute is not eligible for the increase to the micro-purchase threshold. Formal procurement and non competitive procurement policies have been documented; however, formalized documentation supporting the Institute is in compliance with policies did not exist. Additionally, there was no suspension and debarment check completed prior to purchases made with federal funds.
Questioned Costs – Total questioned costs of $45,000 were identified and represents value of equipment purchased for which the procurement process could not be supported in line with the Institute's policy and Uniform Guidance. Context – One purchase of $45,000 out of a total of three purchases totaling $152,986 subject to procurement requirements in 2023 was selected for testing. The Institute could not provide documentation supporting their purchase adhered to policies for formal procurement or non competitive procurement. Furthermore, a check of the vendor's suspension and debarment status prior to the purchase was not completed. The sample was not intended to be, and was not, a statistically valid sample.
Effect – Federal funds could be used to make an unauthorized purchase including paying an entity that is suspended or debarred.
Cause – The Institute's procurement policies are not in accordance with the Uniform Guidance, nor are there controls in place to ensure policies are followed, and lastly, there are no controls to ensure suspension and debarment checks are performed on vendors receiving federal funds.
Identification as a Repeat Finding, if applicable – Not a repeat finding. Recommendation – Policies and procedures should be modified to ensure that procurement policies and suspension and debarment checks on vendors are performed prior to making purchases with federal funds and are in alignment with the Uniform Guidance requirements.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Criteria or Specific Requirement – Procurement and Suspension and Debarment
In accordance with 2 CFR Section 200.320, a non-federal entity must have and use documented procurement procedures consistent with the standards of Sections 200.317 - 200.320. These standards include a micro-purchase threshold of $10,000 and policies for formal procurement and non competitive procurement. Additionally, in accordance with 2 CFR Section 180.220, when a non-federal entity
enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition – The Institute's micro-purchase threshold of $25,000 included in the policy is in excess of
2 CFR Section 200.320, and the Institute is not eligible for the increase to the micro-purchase threshold. Formal procurement and non competitive procurement policies have been documented; however, formalized documentation supporting the Institute is in compliance with policies did not exist. Additionally, there was no suspension and debarment check completed prior to purchases made with federal funds.
Questioned Costs – Total questioned costs of $45,000 were identified and represents value of equipment purchased for which the procurement process could not be supported in line with the Institute's policy and Uniform Guidance. Context – One purchase of $45,000 out of a total of three purchases totaling $152,986 subject to procurement requirements in 2023 was selected for testing. The Institute could not provide documentation supporting their purchase adhered to policies for formal procurement or non competitive procurement. Furthermore, a check of the vendor's suspension and debarment status prior to the purchase was not completed. The sample was not intended to be, and was not, a statistically valid sample.
Effect – Federal funds could be used to make an unauthorized purchase including paying an entity that is suspended or debarred.
Cause – The Institute's procurement policies are not in accordance with the Uniform Guidance, nor are there controls in place to ensure policies are followed, and lastly, there are no controls to ensure suspension and debarment checks are performed on vendors receiving federal funds.
Identification as a Repeat Finding, if applicable – Not a repeat finding. Recommendation – Policies and procedures should be modified to ensure that procurement policies and suspension and debarment checks on vendors are performed prior to making purchases with federal funds and are in alignment with the Uniform Guidance requirements.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Equipment and Real Property Management
In accordance with 2 CFR Section 200.313, a non-federal entity must manage equipment that was procured through the use of federal funds by: maintaining property records, performing a physical inventory once every two years, controls must be implemented to safeguard against loss, and adequate maintenance procedures developed. Condition – During testing of equipment, a complete listing of all property and equipment purchased with federal funds with required information per 2 CFR 200.313(d)(1) was not maintained. A physical inventory of property and equipment was not completed in the past two years.
Questioned Costs – None noted.
Context – The Institute purchased two pieces of equipment totaling $142,986 during 2023. Both pieces of equipment were included in a detail listing of all equipment the Institute maintains. However, during further discussions with the Institute, they were unable to provide a complete listing of equipment purchased through the use of federal funds with all required information.
Effect – Equipment purchased through the use of federal funds is not maintained or disposed of in accordance with the Uniform Guidance.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the equipment policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Equipment and Real Property Management
In accordance with 2 CFR Section 200.313, a non-federal entity must manage equipment that was procured through the use of federal funds by: maintaining property records, performing a physical inventory once every two years, controls must be implemented to safeguard against loss, and adequate maintenance procedures developed. Condition – During testing of equipment, a complete listing of all property and equipment purchased with federal funds with required information per 2 CFR 200.313(d)(1) was not maintained. A physical inventory of property and equipment was not completed in the past two years.
Questioned Costs – None noted.
Context – The Institute purchased two pieces of equipment totaling $142,986 during 2023. Both pieces of equipment were included in a detail listing of all equipment the Institute maintains. However, during further discussions with the Institute, they were unable to provide a complete listing of equipment purchased through the use of federal funds with all required information.
Effect – Equipment purchased through the use of federal funds is not maintained or disposed of in accordance with the Uniform Guidance.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the equipment policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Equipment and Real Property Management
In accordance with 2 CFR Section 200.313, a non-federal entity must manage equipment that was procured through the use of federal funds by: maintaining property records, performing a physical inventory once every two years, controls must be implemented to safeguard against loss, and adequate maintenance procedures developed. Condition – During testing of equipment, a complete listing of all property and equipment purchased with federal funds with required information per 2 CFR 200.313(d)(1) was not maintained. A physical inventory of property and equipment was not completed in the past two years.
Questioned Costs – None noted.
Context – The Institute purchased two pieces of equipment totaling $142,986 during 2023. Both pieces of equipment were included in a detail listing of all equipment the Institute maintains. However, during further discussions with the Institute, they were unable to provide a complete listing of equipment purchased through the use of federal funds with all required information.
Effect – Equipment purchased through the use of federal funds is not maintained or disposed of in accordance with the Uniform Guidance.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the equipment policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Equipment and Real Property Management
In accordance with 2 CFR Section 200.313, a non-federal entity must manage equipment that was procured through the use of federal funds by: maintaining property records, performing a physical inventory once every two years, controls must be implemented to safeguard against loss, and adequate maintenance procedures developed. Condition – During testing of equipment, a complete listing of all property and equipment purchased with federal funds with required information per 2 CFR 200.313(d)(1) was not maintained. A physical inventory of property and equipment was not completed in the past two years.
Questioned Costs – None noted.
Context – The Institute purchased two pieces of equipment totaling $142,986 during 2023. Both pieces of equipment were included in a detail listing of all equipment the Institute maintains. However, during further discussions with the Institute, they were unable to provide a complete listing of equipment purchased through the use of federal funds with all required information.
Effect – Equipment purchased through the use of federal funds is not maintained or disposed of in accordance with the Uniform Guidance.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the equipment policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Equipment and Real Property Management
In accordance with 2 CFR Section 200.313, a non-federal entity must manage equipment that was procured through the use of federal funds by: maintaining property records, performing a physical inventory once every two years, controls must be implemented to safeguard against loss, and adequate maintenance procedures developed. Condition – During testing of equipment, a complete listing of all property and equipment purchased with federal funds with required information per 2 CFR 200.313(d)(1) was not maintained. A physical inventory of property and equipment was not completed in the past two years.
Questioned Costs – None noted.
Context – The Institute purchased two pieces of equipment totaling $142,986 during 2023. Both pieces of equipment were included in a detail listing of all equipment the Institute maintains. However, during further discussions with the Institute, they were unable to provide a complete listing of equipment purchased through the use of federal funds with all required information.
Effect – Equipment purchased through the use of federal funds is not maintained or disposed of in accordance with the Uniform Guidance.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the equipment policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Equipment and Real Property Management
In accordance with 2 CFR Section 200.313, a non-federal entity must manage equipment that was procured through the use of federal funds by: maintaining property records, performing a physical inventory once every two years, controls must be implemented to safeguard against loss, and adequate maintenance procedures developed. Condition – During testing of equipment, a complete listing of all property and equipment purchased with federal funds with required information per 2 CFR 200.313(d)(1) was not maintained. A physical inventory of property and equipment was not completed in the past two years.
Questioned Costs – None noted.
Context – The Institute purchased two pieces of equipment totaling $142,986 during 2023. Both pieces of equipment were included in a detail listing of all equipment the Institute maintains. However, during further discussions with the Institute, they were unable to provide a complete listing of equipment purchased through the use of federal funds with all required information.
Effect – Equipment purchased through the use of federal funds is not maintained or disposed of in accordance with the Uniform Guidance.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the equipment policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Equipment and Real Property Management
In accordance with 2 CFR Section 200.313, a non-federal entity must manage equipment that was procured through the use of federal funds by: maintaining property records, performing a physical inventory once every two years, controls must be implemented to safeguard against loss, and adequate maintenance procedures developed. Condition – During testing of equipment, a complete listing of all property and equipment purchased with federal funds with required information per 2 CFR 200.313(d)(1) was not maintained. A physical inventory of property and equipment was not completed in the past two years.
Questioned Costs – None noted.
Context – The Institute purchased two pieces of equipment totaling $142,986 during 2023. Both pieces of equipment were included in a detail listing of all equipment the Institute maintains. However, during further discussions with the Institute, they were unable to provide a complete listing of equipment purchased through the use of federal funds with all required information.
Effect – Equipment purchased through the use of federal funds is not maintained or disposed of in accordance with the Uniform Guidance.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the equipment policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Equipment and Real Property Management
In accordance with 2 CFR Section 200.313, a non-federal entity must manage equipment that was procured through the use of federal funds by: maintaining property records, performing a physical inventory once every two years, controls must be implemented to safeguard against loss, and adequate maintenance procedures developed. Condition – During testing of equipment, a complete listing of all property and equipment purchased with federal funds with required information per 2 CFR 200.313(d)(1) was not maintained. A physical inventory of property and equipment was not completed in the past two years.
Questioned Costs – None noted.
Context – The Institute purchased two pieces of equipment totaling $142,986 during 2023. Both pieces of equipment were included in a detail listing of all equipment the Institute maintains. However, during further discussions with the Institute, they were unable to provide a complete listing of equipment purchased through the use of federal funds with all required information.
Effect – Equipment purchased through the use of federal funds is not maintained or disposed of in accordance with the Uniform Guidance.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the equipment policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Equipment and Real Property Management
In accordance with 2 CFR Section 200.313, a non-federal entity must manage equipment that was procured through the use of federal funds by: maintaining property records, performing a physical inventory once every two years, controls must be implemented to safeguard against loss, and adequate maintenance procedures developed. Condition – During testing of equipment, a complete listing of all property and equipment purchased with federal funds with required information per 2 CFR 200.313(d)(1) was not maintained. A physical inventory of property and equipment was not completed in the past two years.
Questioned Costs – None noted.
Context – The Institute purchased two pieces of equipment totaling $142,986 during 2023. Both pieces of equipment were included in a detail listing of all equipment the Institute maintains. However, during further discussions with the Institute, they were unable to provide a complete listing of equipment purchased through the use of federal funds with all required information.
Effect – Equipment purchased through the use of federal funds is not maintained or disposed of in accordance with the Uniform Guidance.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the equipment policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Equipment and Real Property Management
In accordance with 2 CFR Section 200.313, a non-federal entity must manage equipment that was procured through the use of federal funds by: maintaining property records, performing a physical inventory once every two years, controls must be implemented to safeguard against loss, and adequate maintenance procedures developed. Condition – During testing of equipment, a complete listing of all property and equipment purchased with federal funds with required information per 2 CFR 200.313(d)(1) was not maintained. A physical inventory of property and equipment was not completed in the past two years.
Questioned Costs – None noted.
Context – The Institute purchased two pieces of equipment totaling $142,986 during 2023. Both pieces of equipment were included in a detail listing of all equipment the Institute maintains. However, during further discussions with the Institute, they were unable to provide a complete listing of equipment purchased through the use of federal funds with all required information.
Effect – Equipment purchased through the use of federal funds is not maintained or disposed of in accordance with the Uniform Guidance.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the equipment policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Equipment and Real Property Management
In accordance with 2 CFR Section 200.313, a non-federal entity must manage equipment that was procured through the use of federal funds by: maintaining property records, performing a physical inventory once every two years, controls must be implemented to safeguard against loss, and adequate maintenance procedures developed. Condition – During testing of equipment, a complete listing of all property and equipment purchased with federal funds with required information per 2 CFR 200.313(d)(1) was not maintained. A physical inventory of property and equipment was not completed in the past two years.
Questioned Costs – None noted.
Context – The Institute purchased two pieces of equipment totaling $142,986 during 2023. Both pieces of equipment were included in a detail listing of all equipment the Institute maintains. However, during further discussions with the Institute, they were unable to provide a complete listing of equipment purchased through the use of federal funds with all required information.
Effect – Equipment purchased through the use of federal funds is not maintained or disposed of in accordance with the Uniform Guidance.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the equipment policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Special Test - Key Personnel
In accordance with 2 CFR Section 200.308(c)(2) and (3), for non-construction federal awards, recipients must request prior approvals from federal awarding agencies for the change in a key person specified in the application or the federal award or the disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
Condition – During testing, we did not identify any requests for changes or disengagement of key personnel.
Questioned Costs – None noted.
Context – During testing of key personnel, three individuals were included in the project budget for grant 2020-68012-31934 (ALN # 10.310) and only two were noted to have participated in the project during the year. The Institute provided support for the disengagement of one key personnel that was reported to the grantor; however, the reporting occurred after the fact rather than receiving prior approval as required by the Uniform Guidance. Effect – The disengagement of a named key person may have occurred without prior approval.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the key personnel policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Special Test - Key Personnel
In accordance with 2 CFR Section 200.308(c)(2) and (3), for non-construction federal awards, recipients must request prior approvals from federal awarding agencies for the change in a key person specified in the application or the federal award or the disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
Condition – During testing, we did not identify any requests for changes or disengagement of key personnel.
Questioned Costs – None noted.
Context – During testing of key personnel, three individuals were included in the project budget for grant 2020-68012-31934 (ALN # 10.310) and only two were noted to have participated in the project during the year. The Institute provided support for the disengagement of one key personnel that was reported to the grantor; however, the reporting occurred after the fact rather than receiving prior approval as required by the Uniform Guidance. Effect – The disengagement of a named key person may have occurred without prior approval.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the key personnel policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Special Test - Key Personnel
In accordance with 2 CFR Section 200.308(c)(2) and (3), for non-construction federal awards, recipients must request prior approvals from federal awarding agencies for the change in a key person specified in the application or the federal award or the disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
Condition – During testing, we did not identify any requests for changes or disengagement of key personnel.
Questioned Costs – None noted.
Context – During testing of key personnel, three individuals were included in the project budget for grant 2020-68012-31934 (ALN # 10.310) and only two were noted to have participated in the project during the year. The Institute provided support for the disengagement of one key personnel that was reported to the grantor; however, the reporting occurred after the fact rather than receiving prior approval as required by the Uniform Guidance. Effect – The disengagement of a named key person may have occurred without prior approval.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the key personnel policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Special Test - Key Personnel
In accordance with 2 CFR Section 200.308(c)(2) and (3), for non-construction federal awards, recipients must request prior approvals from federal awarding agencies for the change in a key person specified in the application or the federal award or the disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
Condition – During testing, we did not identify any requests for changes or disengagement of key personnel.
Questioned Costs – None noted.
Context – During testing of key personnel, three individuals were included in the project budget for grant 2020-68012-31934 (ALN # 10.310) and only two were noted to have participated in the project during the year. The Institute provided support for the disengagement of one key personnel that was reported to the grantor; however, the reporting occurred after the fact rather than receiving prior approval as required by the Uniform Guidance. Effect – The disengagement of a named key person may have occurred without prior approval.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the key personnel policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Special Test - Key Personnel
In accordance with 2 CFR Section 200.308(c)(2) and (3), for non-construction federal awards, recipients must request prior approvals from federal awarding agencies for the change in a key person specified in the application or the federal award or the disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
Condition – During testing, we did not identify any requests for changes or disengagement of key personnel.
Questioned Costs – None noted.
Context – During testing of key personnel, three individuals were included in the project budget for grant 2020-68012-31934 (ALN # 10.310) and only two were noted to have participated in the project during the year. The Institute provided support for the disengagement of one key personnel that was reported to the grantor; however, the reporting occurred after the fact rather than receiving prior approval as required by the Uniform Guidance. Effect – The disengagement of a named key person may have occurred without prior approval.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the key personnel policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Special Test - Key Personnel
In accordance with 2 CFR Section 200.308(c)(2) and (3), for non-construction federal awards, recipients must request prior approvals from federal awarding agencies for the change in a key person specified in the application or the federal award or the disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
Condition – During testing, we did not identify any requests for changes or disengagement of key personnel.
Questioned Costs – None noted.
Context – During testing of key personnel, three individuals were included in the project budget for grant 2020-68012-31934 (ALN # 10.310) and only two were noted to have participated in the project during the year. The Institute provided support for the disengagement of one key personnel that was reported to the grantor; however, the reporting occurred after the fact rather than receiving prior approval as required by the Uniform Guidance. Effect – The disengagement of a named key person may have occurred without prior approval.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the key personnel policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Special Test - Key Personnel
In accordance with 2 CFR Section 200.308(c)(2) and (3), for non-construction federal awards, recipients must request prior approvals from federal awarding agencies for the change in a key person specified in the application or the federal award or the disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
Condition – During testing, we did not identify any requests for changes or disengagement of key personnel.
Questioned Costs – None noted.
Context – During testing of key personnel, three individuals were included in the project budget for grant 2020-68012-31934 (ALN # 10.310) and only two were noted to have participated in the project during the year. The Institute provided support for the disengagement of one key personnel that was reported to the grantor; however, the reporting occurred after the fact rather than receiving prior approval as required by the Uniform Guidance. Effect – The disengagement of a named key person may have occurred without prior approval.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the key personnel policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Special Test - Key Personnel
In accordance with 2 CFR Section 200.308(c)(2) and (3), for non-construction federal awards, recipients must request prior approvals from federal awarding agencies for the change in a key person specified in the application or the federal award or the disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
Condition – During testing, we did not identify any requests for changes or disengagement of key personnel.
Questioned Costs – None noted.
Context – During testing of key personnel, three individuals were included in the project budget for grant 2020-68012-31934 (ALN # 10.310) and only two were noted to have participated in the project during the year. The Institute provided support for the disengagement of one key personnel that was reported to the grantor; however, the reporting occurred after the fact rather than receiving prior approval as required by the Uniform Guidance. Effect – The disengagement of a named key person may have occurred without prior approval.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the key personnel policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Special Test - Key Personnel
In accordance with 2 CFR Section 200.308(c)(2) and (3), for non-construction federal awards, recipients must request prior approvals from federal awarding agencies for the change in a key person specified in the application or the federal award or the disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
Condition – During testing, we did not identify any requests for changes or disengagement of key personnel.
Questioned Costs – None noted.
Context – During testing of key personnel, three individuals were included in the project budget for grant 2020-68012-31934 (ALN # 10.310) and only two were noted to have participated in the project during the year. The Institute provided support for the disengagement of one key personnel that was reported to the grantor; however, the reporting occurred after the fact rather than receiving prior approval as required by the Uniform Guidance. Effect – The disengagement of a named key person may have occurred without prior approval.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the key personnel policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Special Test - Key Personnel
In accordance with 2 CFR Section 200.308(c)(2) and (3), for non-construction federal awards, recipients must request prior approvals from federal awarding agencies for the change in a key person specified in the application or the federal award or the disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
Condition – During testing, we did not identify any requests for changes or disengagement of key personnel.
Questioned Costs – None noted.
Context – During testing of key personnel, three individuals were included in the project budget for grant 2020-68012-31934 (ALN # 10.310) and only two were noted to have participated in the project during the year. The Institute provided support for the disengagement of one key personnel that was reported to the grantor; however, the reporting occurred after the fact rather than receiving prior approval as required by the Uniform Guidance. Effect – The disengagement of a named key person may have occurred without prior approval.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the key personnel policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods
Criteria or Specific Requirement – Special Test - Key Personnel
In accordance with 2 CFR Section 200.308(c)(2) and (3), for non-construction federal awards, recipients must request prior approvals from federal awarding agencies for the change in a key person specified in the application or the federal award or the disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
Condition – During testing, we did not identify any requests for changes or disengagement of key personnel.
Questioned Costs – None noted.
Context – During testing of key personnel, three individuals were included in the project budget for grant 2020-68012-31934 (ALN # 10.310) and only two were noted to have participated in the project during the year. The Institute provided support for the disengagement of one key personnel that was reported to the grantor; however, the reporting occurred after the fact rather than receiving prior approval as required by the Uniform Guidance. Effect – The disengagement of a named key person may have occurred without prior approval.
Cause – The Institute's misunderstanding of the requirements.
Identification as a Repeat Finding, if applicable – Not a repeat finding.
Recommendation – Policies and procedures should be modified to ensure that management understands the key personnel policies and procedures outlined by the Uniform Guidance and that the Institute is in compliance.
Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.