Audit 317514

FY End
2023-12-31
Total Expended
$1.23M
Findings
14
Programs
8
Organization: American Bureau of Shipping (TX)
Year: 2023 Accepted: 2024-08-20

Organization Exclusion Status:

Checking exclusion status...

Contacts

Name Title Type
MMU8RZF8HMH9 Domenic Carlucci Auditee
8323168764 Melissa Wakeland Auditor
No contacts on file

Notes to SEFA

Title: Basis of Presentation Accounting Policies: The accompanying schedule of expenditures of federal awards (the "Schedule") is presented on the accrual basis of accounting. The purpose of this schedule is to present a summary of those activities of American Bureau of Shipping for the year ended December 31, 2023, which have been financed by the United States government ("federal awards"). For purposes of this Schedule, federal awards include all federal assistance awarded directly between American Bureau of Shipping and the federal government and subawards from nonfederal organizations made under federally sponsored agreements. The information in this Schedule is presented in accordance with the requirements of Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Pass-through entity identification numbers and Assistance Listing numbers have been provided where available. De Minimis Rate Used: Both Rate Explanation: Except where the federal award contains an indirect rate restriction, American Bureau of Shipping has not elected to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The amount claimed as indirect cost recovery uses a sliding scale of indirect cost rate as negotiated and approved individually in each award. The accompanying schedule of expenditures of federal awards (the "Schedule") is presented on the accrual basis of accounting. The purpose of this schedule is to present a summary of those activities of American Bureau of Shipping for the year ended December 31, 2023, which have been financed by the United States government ("federal awards"). For purposes of this Schedule, federal awards include all federal assistance awarded directly between American Bureau of Shipping and the federal government and subawards from nonfederal organizations made under federally sponsored agreements. The information in this Schedule is presented in accordance with the requirements of Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Pass-through entity identification numbers and Assistance Listing numbers have been provided where available.
Title: Indirect Cost Rate Accounting Policies: The accompanying schedule of expenditures of federal awards (the "Schedule") is presented on the accrual basis of accounting. The purpose of this schedule is to present a summary of those activities of American Bureau of Shipping for the year ended December 31, 2023, which have been financed by the United States government ("federal awards"). For purposes of this Schedule, federal awards include all federal assistance awarded directly between American Bureau of Shipping and the federal government and subawards from nonfederal organizations made under federally sponsored agreements. The information in this Schedule is presented in accordance with the requirements of Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Pass-through entity identification numbers and Assistance Listing numbers have been provided where available. De Minimis Rate Used: Both Rate Explanation: Except where the federal award contains an indirect rate restriction, American Bureau of Shipping has not elected to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The amount claimed as indirect cost recovery uses a sliding scale of indirect cost rate as negotiated and approved individually in each award. Except where the federal award contains an indirect rate restriction, American Bureau of Shipping has not elected to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The amount claimed as indirect cost recovery uses a sliding scale of indirect cost rate as negotiated and approved individually in each award.

Finding Details

Cluster: Research and Development Agency: Department of Human and Health Services Award Names: Safety and Health Risks in Energy Transition for the Commercial Fishing Industry Award Numbers: U01OH012502 Assistance Listing Title: Center for Disease Control and Prevention (CDC) Assistance Listing Number: 93.262 Award Year: FY 2023 Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Condition Through our testing of 4 subrecipients out of a total subrecipient population of 10, we were able to obtain a documented initial risk assessment for each subrecipient selected and other evidence of monitoring such as meetings with the subrecipients. However, we were unable to obtain evidence that the Company obtained and reviewed the annual Uniform Guidance report or annual audited financial statements (if the entity was not subject to a Uniform Guidance audit) for 1 out of 4 subrecipients selected for testing. Cause The Company failed to ensure that their subrecipient monitoring process included obtaining and reviewing every subrecipient’s annual Uniform Guidance report or annual audited financial statements during FY 2023. Effect The lack of an annual review of subrecipient audits may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend the Company follow their policy, which includes obtaining and reviewing Uniform Guidance reports (or audited financial statements to the extent Uniform Guidance reports are not available) for every subrecipient on an annual basis and ensure that it is completed for all applicable awards. When reviewing the reports, they should understand the type of opinion(s) expressed and whether there were any findings associated with their awards, document their review and assess whether there is any change in the risk assessment and subsequent monitoring needed of each subrecipient. We also recommend a supervisory review over subrecipient monitoring to be included in the process to ensure it gets completed completely and accurately for all awards. This supervisory review should also be evidenced through documentation. This is a repeat finding of 2022-001, which continued to remain open during FY2023. Management’ Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report.
Cluster: Research and Development Supporting Agency: Department of Commerce, Department of Energy, and Department of Human and Health Services Award Names: Standards/Guidance for Rapid Qualification of Metal-Based Additive Manufacturing, Accelerating Commercial Maritime Demonstration Projects for Advanced Nuclear Reactor Technologies, Safety and Health Risks in Energy Transition for the Commercial Fishing Industry, The NASA Floater: 15MW Ultra-lightweight Concrete Hull with Sea-Water Ballast Tuned Mass Dampers, Scale model Experiments for Co-Designed FOWTs Supporting A High-Capacity (15 MW) Turbine, Demonstrating a Reduced-Footprint Synthetic Rope Mooring System that Minimizes Fishing Impacts and Costs for a 10MW+ Floating Wind Turbine Award Numbers: 70NANB21H038, DE-NE0009226, U01OH012502, UMS-1258, ABS-061720, and FOA- 2236 Assistance Listing Title: National Institute of Standards and Technology, Office of Nuclear Energy, Advanced Research Projects Agency, Office of Energy Efficiency and Renewable Energy, Center for Disease Control and Prevention (CDC) Assistance Listing Number: 11.609, 81.121, 81.135, 81.087, 93.262 Award Year: FY 2023 Criteria 2 CFR 200.303 notes that a non-Federal entity must: 1. Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2.Evaluate and monitor the non-Federal entity’s compliance with statutes, regulations, and the terms and conditions of Federal awards. We note that with regards to the Company’s internal controls over Federal awards, a monthly budget to actual review is to be performed and review evidenced for each grant to monitor grant activity, including allowability. Condition We selected 6 quarters out of a population of 61 quarters across the Research and Development Cluster awards for testing to evidence that a budget to actual review was being performed, as required by Company policy. Through our testing, we noted 6 instances where appropriate supporting documentation was not maintained to support that the budget to actual review was performed. We noted through inquiry of management that for each selection, a review of expenses was performed but evidence was not formally maintained of the budget to actual review. However, when reviewing the award budget and cumulative expenses incurred on the award for each selection, it was noted that each quarter selected was within budget. Cause The Company indicated budget to actual monitoring and reviews were not consistently performed due to a lack of clarity in the Company policy. The Company policy did not clearly articulate the process owners by activity and was updated in Q4 2023, therefore responsible parties were not aware of this required activity. Effect Lack of executing this control could result in ineligible costs being submitted for payment and jobs going above the agreed upon budget. Questioned Costs None noted. Recommendation We recommend the Company review their policies and ensure appropriate communication and coordination amongst relevant parties to ensure the budget to actual review is performed according to policy and appropriate documentation is maintained. This is a repeat finding of 2022-002, which continued to remain open during FY2023. Management’ Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report.
Cluster: Research and Development Supporting Agency: Department of Commerce, Department of Energy, and Department of Human and Health Services Award Names: Standards/Guidance for Rapid Qualification of Metal-Based Additive Manufacturing, Accelerating Commercial Maritime Demonstration Projects for Advanced Nuclear Reactor Technologies, Safety and Health Risks in Energy Transition for the Commercial Fishing Industry, The NASA Floater: 15MW Ultra-lightweight Concrete Hull with Sea-Water Ballast Tuned Mass Dampers, Scale model Experiments for Co-Designed FOWTs Supporting A High-Capacity (15 MW) Turbine, Demonstrating a Reduced-Footprint Synthetic Rope Mooring System that Minimizes Fishing Impacts and Costs for a 10MW+ Floating Wind Turbine Award Numbers: 70NANB21H038, DE-NE0009226, U01OH012502, UMS-1258, ABS-061720, and FOA- 2236 Assistance Listing Title: National Institute of Standards and Technology, Office of Nuclear Energy, Advanced Research Projects Agency, Office of Energy Efficiency and Renewable Energy, Center for Disease Control and Prevention (CDC) Assistance Listing Number: 11.609, 81.121, 81.135, 81.087, 93.262 Award Year: FY 2023 Criteria 2 CFR 200.303 notes that a non-Federal entity must: 1. Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2.Evaluate and monitor the non-Federal entity’s compliance with statutes, regulations, and the terms and conditions of Federal awards. We note that with regards to the Company’s internal controls over Federal awards, a monthly budget to actual review is to be performed and review evidenced for each grant to monitor grant activity, including allowability. Condition We selected 6 quarters out of a population of 61 quarters across the Research and Development Cluster awards for testing to evidence that a budget to actual review was being performed, as required by Company policy. Through our testing, we noted 6 instances where appropriate supporting documentation was not maintained to support that the budget to actual review was performed. We noted through inquiry of management that for each selection, a review of expenses was performed but evidence was not formally maintained of the budget to actual review. However, when reviewing the award budget and cumulative expenses incurred on the award for each selection, it was noted that each quarter selected was within budget. Cause The Company indicated budget to actual monitoring and reviews were not consistently performed due to a lack of clarity in the Company policy. The Company policy did not clearly articulate the process owners by activity and was updated in Q4 2023, therefore responsible parties were not aware of this required activity. Effect Lack of executing this control could result in ineligible costs being submitted for payment and jobs going above the agreed upon budget. Questioned Costs None noted. Recommendation We recommend the Company review their policies and ensure appropriate communication and coordination amongst relevant parties to ensure the budget to actual review is performed according to policy and appropriate documentation is maintained. This is a repeat finding of 2022-002, which continued to remain open during FY2023. Management’ Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report.
Cluster: Research and Development Supporting Agency: Department of Commerce, Department of Energy, and Department of Human and Health Services Award Names: Standards/Guidance for Rapid Qualification of Metal-Based Additive Manufacturing, Accelerating Commercial Maritime Demonstration Projects for Advanced Nuclear Reactor Technologies, Safety and Health Risks in Energy Transition for the Commercial Fishing Industry, The NASA Floater: 15MW Ultra-lightweight Concrete Hull with Sea-Water Ballast Tuned Mass Dampers, Scale model Experiments for Co-Designed FOWTs Supporting A High-Capacity (15 MW) Turbine, Demonstrating a Reduced-Footprint Synthetic Rope Mooring System that Minimizes Fishing Impacts and Costs for a 10MW+ Floating Wind Turbine Award Numbers: 70NANB21H038, DE-NE0009226, U01OH012502, UMS-1258, ABS-061720, and FOA- 2236 Assistance Listing Title: National Institute of Standards and Technology, Office of Nuclear Energy, Advanced Research Projects Agency, Office of Energy Efficiency and Renewable Energy, Center for Disease Control and Prevention (CDC) Assistance Listing Number: 11.609, 81.121, 81.135, 81.087, 93.262 Award Year: FY 2023 Criteria 2 CFR 200.303 notes that a non-Federal entity must: 1. Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2.Evaluate and monitor the non-Federal entity’s compliance with statutes, regulations, and the terms and conditions of Federal awards. We note that with regards to the Company’s internal controls over Federal awards, a monthly budget to actual review is to be performed and review evidenced for each grant to monitor grant activity, including allowability. Condition We selected 6 quarters out of a population of 61 quarters across the Research and Development Cluster awards for testing to evidence that a budget to actual review was being performed, as required by Company policy. Through our testing, we noted 6 instances where appropriate supporting documentation was not maintained to support that the budget to actual review was performed. We noted through inquiry of management that for each selection, a review of expenses was performed but evidence was not formally maintained of the budget to actual review. However, when reviewing the award budget and cumulative expenses incurred on the award for each selection, it was noted that each quarter selected was within budget. Cause The Company indicated budget to actual monitoring and reviews were not consistently performed due to a lack of clarity in the Company policy. The Company policy did not clearly articulate the process owners by activity and was updated in Q4 2023, therefore responsible parties were not aware of this required activity. Effect Lack of executing this control could result in ineligible costs being submitted for payment and jobs going above the agreed upon budget. Questioned Costs None noted. Recommendation We recommend the Company review their policies and ensure appropriate communication and coordination amongst relevant parties to ensure the budget to actual review is performed according to policy and appropriate documentation is maintained. This is a repeat finding of 2022-002, which continued to remain open during FY2023. Management’ Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report.
Cluster: Research and Development Supporting Agency: Department of Commerce, Department of Energy, and Department of Human and Health Services Award Names: Standards/Guidance for Rapid Qualification of Metal-Based Additive Manufacturing, Accelerating Commercial Maritime Demonstration Projects for Advanced Nuclear Reactor Technologies, Safety and Health Risks in Energy Transition for the Commercial Fishing Industry, The NASA Floater: 15MW Ultra-lightweight Concrete Hull with Sea-Water Ballast Tuned Mass Dampers, Scale model Experiments for Co-Designed FOWTs Supporting A High-Capacity (15 MW) Turbine, Demonstrating a Reduced-Footprint Synthetic Rope Mooring System that Minimizes Fishing Impacts and Costs for a 10MW+ Floating Wind Turbine Award Numbers: 70NANB21H038, DE-NE0009226, U01OH012502, UMS-1258, ABS-061720, and FOA- 2236 Assistance Listing Title: National Institute of Standards and Technology, Office of Nuclear Energy, Advanced Research Projects Agency, Office of Energy Efficiency and Renewable Energy, Center for Disease Control and Prevention (CDC) Assistance Listing Number: 11.609, 81.121, 81.135, 81.087, 93.262 Award Year: FY 2023 Criteria 2 CFR 200.303 notes that a non-Federal entity must: 1. Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2.Evaluate and monitor the non-Federal entity’s compliance with statutes, regulations, and the terms and conditions of Federal awards. We note that with regards to the Company’s internal controls over Federal awards, a monthly budget to actual review is to be performed and review evidenced for each grant to monitor grant activity, including allowability. Condition We selected 6 quarters out of a population of 61 quarters across the Research and Development Cluster awards for testing to evidence that a budget to actual review was being performed, as required by Company policy. Through our testing, we noted 6 instances where appropriate supporting documentation was not maintained to support that the budget to actual review was performed. We noted through inquiry of management that for each selection, a review of expenses was performed but evidence was not formally maintained of the budget to actual review. However, when reviewing the award budget and cumulative expenses incurred on the award for each selection, it was noted that each quarter selected was within budget. Cause The Company indicated budget to actual monitoring and reviews were not consistently performed due to a lack of clarity in the Company policy. The Company policy did not clearly articulate the process owners by activity and was updated in Q4 2023, therefore responsible parties were not aware of this required activity. Effect Lack of executing this control could result in ineligible costs being submitted for payment and jobs going above the agreed upon budget. Questioned Costs None noted. Recommendation We recommend the Company review their policies and ensure appropriate communication and coordination amongst relevant parties to ensure the budget to actual review is performed according to policy and appropriate documentation is maintained. This is a repeat finding of 2022-002, which continued to remain open during FY2023. Management’ Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report.
Cluster: Research and Development Supporting Agency: Department of Commerce, Department of Energy, and Department of Human and Health Services Award Names: Standards/Guidance for Rapid Qualification of Metal-Based Additive Manufacturing, Accelerating Commercial Maritime Demonstration Projects for Advanced Nuclear Reactor Technologies, Safety and Health Risks in Energy Transition for the Commercial Fishing Industry, The NASA Floater: 15MW Ultra-lightweight Concrete Hull with Sea-Water Ballast Tuned Mass Dampers, Scale model Experiments for Co-Designed FOWTs Supporting A High-Capacity (15 MW) Turbine, Demonstrating a Reduced-Footprint Synthetic Rope Mooring System that Minimizes Fishing Impacts and Costs for a 10MW+ Floating Wind Turbine Award Numbers: 70NANB21H038, DE-NE0009226, U01OH012502, UMS-1258, ABS-061720, and FOA- 2236 Assistance Listing Title: National Institute of Standards and Technology, Office of Nuclear Energy, Advanced Research Projects Agency, Office of Energy Efficiency and Renewable Energy, Center for Disease Control and Prevention (CDC) Assistance Listing Number: 11.609, 81.121, 81.135, 81.087, 93.262 Award Year: FY 2023 Criteria 2 CFR 200.303 notes that a non-Federal entity must: 1. Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2.Evaluate and monitor the non-Federal entity’s compliance with statutes, regulations, and the terms and conditions of Federal awards. We note that with regards to the Company’s internal controls over Federal awards, a monthly budget to actual review is to be performed and review evidenced for each grant to monitor grant activity, including allowability. Condition We selected 6 quarters out of a population of 61 quarters across the Research and Development Cluster awards for testing to evidence that a budget to actual review was being performed, as required by Company policy. Through our testing, we noted 6 instances where appropriate supporting documentation was not maintained to support that the budget to actual review was performed. We noted through inquiry of management that for each selection, a review of expenses was performed but evidence was not formally maintained of the budget to actual review. However, when reviewing the award budget and cumulative expenses incurred on the award for each selection, it was noted that each quarter selected was within budget. Cause The Company indicated budget to actual monitoring and reviews were not consistently performed due to a lack of clarity in the Company policy. The Company policy did not clearly articulate the process owners by activity and was updated in Q4 2023, therefore responsible parties were not aware of this required activity. Effect Lack of executing this control could result in ineligible costs being submitted for payment and jobs going above the agreed upon budget. Questioned Costs None noted. Recommendation We recommend the Company review their policies and ensure appropriate communication and coordination amongst relevant parties to ensure the budget to actual review is performed according to policy and appropriate documentation is maintained. This is a repeat finding of 2022-002, which continued to remain open during FY2023. Management’ Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report.
Cluster: Research and Development Supporting Agency: Department of Commerce, Department of Energy, and Department of Human and Health Services Award Names: Standards/Guidance for Rapid Qualification of Metal-Based Additive Manufacturing, Accelerating Commercial Maritime Demonstration Projects for Advanced Nuclear Reactor Technologies, Safety and Health Risks in Energy Transition for the Commercial Fishing Industry, The NASA Floater: 15MW Ultra-lightweight Concrete Hull with Sea-Water Ballast Tuned Mass Dampers, Scale model Experiments for Co-Designed FOWTs Supporting A High-Capacity (15 MW) Turbine, Demonstrating a Reduced-Footprint Synthetic Rope Mooring System that Minimizes Fishing Impacts and Costs for a 10MW+ Floating Wind Turbine Award Numbers: 70NANB21H038, DE-NE0009226, U01OH012502, UMS-1258, ABS-061720, and FOA- 2236 Assistance Listing Title: National Institute of Standards and Technology, Office of Nuclear Energy, Advanced Research Projects Agency, Office of Energy Efficiency and Renewable Energy, Center for Disease Control and Prevention (CDC) Assistance Listing Number: 11.609, 81.121, 81.135, 81.087, 93.262 Award Year: FY 2023 Criteria 2 CFR 200.303 notes that a non-Federal entity must: 1. Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2.Evaluate and monitor the non-Federal entity’s compliance with statutes, regulations, and the terms and conditions of Federal awards. We note that with regards to the Company’s internal controls over Federal awards, a monthly budget to actual review is to be performed and review evidenced for each grant to monitor grant activity, including allowability. Condition We selected 6 quarters out of a population of 61 quarters across the Research and Development Cluster awards for testing to evidence that a budget to actual review was being performed, as required by Company policy. Through our testing, we noted 6 instances where appropriate supporting documentation was not maintained to support that the budget to actual review was performed. We noted through inquiry of management that for each selection, a review of expenses was performed but evidence was not formally maintained of the budget to actual review. However, when reviewing the award budget and cumulative expenses incurred on the award for each selection, it was noted that each quarter selected was within budget. Cause The Company indicated budget to actual monitoring and reviews were not consistently performed due to a lack of clarity in the Company policy. The Company policy did not clearly articulate the process owners by activity and was updated in Q4 2023, therefore responsible parties were not aware of this required activity. Effect Lack of executing this control could result in ineligible costs being submitted for payment and jobs going above the agreed upon budget. Questioned Costs None noted. Recommendation We recommend the Company review their policies and ensure appropriate communication and coordination amongst relevant parties to ensure the budget to actual review is performed according to policy and appropriate documentation is maintained. This is a repeat finding of 2022-002, which continued to remain open during FY2023. Management’ Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report.
Cluster: Research and Development Agency: Department of Human and Health Services Award Names: Safety and Health Risks in Energy Transition for the Commercial Fishing Industry Award Numbers: U01OH012502 Assistance Listing Title: Center for Disease Control and Prevention (CDC) Assistance Listing Number: 93.262 Award Year: FY 2023 Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Condition Through our testing of 4 subrecipients out of a total subrecipient population of 10, we were able to obtain a documented initial risk assessment for each subrecipient selected and other evidence of monitoring such as meetings with the subrecipients. However, we were unable to obtain evidence that the Company obtained and reviewed the annual Uniform Guidance report or annual audited financial statements (if the entity was not subject to a Uniform Guidance audit) for 1 out of 4 subrecipients selected for testing. Cause The Company failed to ensure that their subrecipient monitoring process included obtaining and reviewing every subrecipient’s annual Uniform Guidance report or annual audited financial statements during FY 2023. Effect The lack of an annual review of subrecipient audits may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend the Company follow their policy, which includes obtaining and reviewing Uniform Guidance reports (or audited financial statements to the extent Uniform Guidance reports are not available) for every subrecipient on an annual basis and ensure that it is completed for all applicable awards. When reviewing the reports, they should understand the type of opinion(s) expressed and whether there were any findings associated with their awards, document their review and assess whether there is any change in the risk assessment and subsequent monitoring needed of each subrecipient. We also recommend a supervisory review over subrecipient monitoring to be included in the process to ensure it gets completed completely and accurately for all awards. This supervisory review should also be evidenced through documentation. This is a repeat finding of 2022-001, which continued to remain open during FY2023. Management’ Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report.
Cluster: Research and Development Supporting Agency: Department of Commerce, Department of Energy, and Department of Human and Health Services Award Names: Standards/Guidance for Rapid Qualification of Metal-Based Additive Manufacturing, Accelerating Commercial Maritime Demonstration Projects for Advanced Nuclear Reactor Technologies, Safety and Health Risks in Energy Transition for the Commercial Fishing Industry, The NASA Floater: 15MW Ultra-lightweight Concrete Hull with Sea-Water Ballast Tuned Mass Dampers, Scale model Experiments for Co-Designed FOWTs Supporting A High-Capacity (15 MW) Turbine, Demonstrating a Reduced-Footprint Synthetic Rope Mooring System that Minimizes Fishing Impacts and Costs for a 10MW+ Floating Wind Turbine Award Numbers: 70NANB21H038, DE-NE0009226, U01OH012502, UMS-1258, ABS-061720, and FOA- 2236 Assistance Listing Title: National Institute of Standards and Technology, Office of Nuclear Energy, Advanced Research Projects Agency, Office of Energy Efficiency and Renewable Energy, Center for Disease Control and Prevention (CDC) Assistance Listing Number: 11.609, 81.121, 81.135, 81.087, 93.262 Award Year: FY 2023 Criteria 2 CFR 200.303 notes that a non-Federal entity must: 1. Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2.Evaluate and monitor the non-Federal entity’s compliance with statutes, regulations, and the terms and conditions of Federal awards. We note that with regards to the Company’s internal controls over Federal awards, a monthly budget to actual review is to be performed and review evidenced for each grant to monitor grant activity, including allowability. Condition We selected 6 quarters out of a population of 61 quarters across the Research and Development Cluster awards for testing to evidence that a budget to actual review was being performed, as required by Company policy. Through our testing, we noted 6 instances where appropriate supporting documentation was not maintained to support that the budget to actual review was performed. We noted through inquiry of management that for each selection, a review of expenses was performed but evidence was not formally maintained of the budget to actual review. However, when reviewing the award budget and cumulative expenses incurred on the award for each selection, it was noted that each quarter selected was within budget. Cause The Company indicated budget to actual monitoring and reviews were not consistently performed due to a lack of clarity in the Company policy. The Company policy did not clearly articulate the process owners by activity and was updated in Q4 2023, therefore responsible parties were not aware of this required activity. Effect Lack of executing this control could result in ineligible costs being submitted for payment and jobs going above the agreed upon budget. Questioned Costs None noted. Recommendation We recommend the Company review their policies and ensure appropriate communication and coordination amongst relevant parties to ensure the budget to actual review is performed according to policy and appropriate documentation is maintained. This is a repeat finding of 2022-002, which continued to remain open during FY2023. Management’ Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report.
Cluster: Research and Development Supporting Agency: Department of Commerce, Department of Energy, and Department of Human and Health Services Award Names: Standards/Guidance for Rapid Qualification of Metal-Based Additive Manufacturing, Accelerating Commercial Maritime Demonstration Projects for Advanced Nuclear Reactor Technologies, Safety and Health Risks in Energy Transition for the Commercial Fishing Industry, The NASA Floater: 15MW Ultra-lightweight Concrete Hull with Sea-Water Ballast Tuned Mass Dampers, Scale model Experiments for Co-Designed FOWTs Supporting A High-Capacity (15 MW) Turbine, Demonstrating a Reduced-Footprint Synthetic Rope Mooring System that Minimizes Fishing Impacts and Costs for a 10MW+ Floating Wind Turbine Award Numbers: 70NANB21H038, DE-NE0009226, U01OH012502, UMS-1258, ABS-061720, and FOA- 2236 Assistance Listing Title: National Institute of Standards and Technology, Office of Nuclear Energy, Advanced Research Projects Agency, Office of Energy Efficiency and Renewable Energy, Center for Disease Control and Prevention (CDC) Assistance Listing Number: 11.609, 81.121, 81.135, 81.087, 93.262 Award Year: FY 2023 Criteria 2 CFR 200.303 notes that a non-Federal entity must: 1. Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2.Evaluate and monitor the non-Federal entity’s compliance with statutes, regulations, and the terms and conditions of Federal awards. We note that with regards to the Company’s internal controls over Federal awards, a monthly budget to actual review is to be performed and review evidenced for each grant to monitor grant activity, including allowability. Condition We selected 6 quarters out of a population of 61 quarters across the Research and Development Cluster awards for testing to evidence that a budget to actual review was being performed, as required by Company policy. Through our testing, we noted 6 instances where appropriate supporting documentation was not maintained to support that the budget to actual review was performed. We noted through inquiry of management that for each selection, a review of expenses was performed but evidence was not formally maintained of the budget to actual review. However, when reviewing the award budget and cumulative expenses incurred on the award for each selection, it was noted that each quarter selected was within budget. Cause The Company indicated budget to actual monitoring and reviews were not consistently performed due to a lack of clarity in the Company policy. The Company policy did not clearly articulate the process owners by activity and was updated in Q4 2023, therefore responsible parties were not aware of this required activity. Effect Lack of executing this control could result in ineligible costs being submitted for payment and jobs going above the agreed upon budget. Questioned Costs None noted. Recommendation We recommend the Company review their policies and ensure appropriate communication and coordination amongst relevant parties to ensure the budget to actual review is performed according to policy and appropriate documentation is maintained. This is a repeat finding of 2022-002, which continued to remain open during FY2023. Management’ Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report.
Cluster: Research and Development Supporting Agency: Department of Commerce, Department of Energy, and Department of Human and Health Services Award Names: Standards/Guidance for Rapid Qualification of Metal-Based Additive Manufacturing, Accelerating Commercial Maritime Demonstration Projects for Advanced Nuclear Reactor Technologies, Safety and Health Risks in Energy Transition for the Commercial Fishing Industry, The NASA Floater: 15MW Ultra-lightweight Concrete Hull with Sea-Water Ballast Tuned Mass Dampers, Scale model Experiments for Co-Designed FOWTs Supporting A High-Capacity (15 MW) Turbine, Demonstrating a Reduced-Footprint Synthetic Rope Mooring System that Minimizes Fishing Impacts and Costs for a 10MW+ Floating Wind Turbine Award Numbers: 70NANB21H038, DE-NE0009226, U01OH012502, UMS-1258, ABS-061720, and FOA- 2236 Assistance Listing Title: National Institute of Standards and Technology, Office of Nuclear Energy, Advanced Research Projects Agency, Office of Energy Efficiency and Renewable Energy, Center for Disease Control and Prevention (CDC) Assistance Listing Number: 11.609, 81.121, 81.135, 81.087, 93.262 Award Year: FY 2023 Criteria 2 CFR 200.303 notes that a non-Federal entity must: 1. Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2.Evaluate and monitor the non-Federal entity’s compliance with statutes, regulations, and the terms and conditions of Federal awards. We note that with regards to the Company’s internal controls over Federal awards, a monthly budget to actual review is to be performed and review evidenced for each grant to monitor grant activity, including allowability. Condition We selected 6 quarters out of a population of 61 quarters across the Research and Development Cluster awards for testing to evidence that a budget to actual review was being performed, as required by Company policy. Through our testing, we noted 6 instances where appropriate supporting documentation was not maintained to support that the budget to actual review was performed. We noted through inquiry of management that for each selection, a review of expenses was performed but evidence was not formally maintained of the budget to actual review. However, when reviewing the award budget and cumulative expenses incurred on the award for each selection, it was noted that each quarter selected was within budget. Cause The Company indicated budget to actual monitoring and reviews were not consistently performed due to a lack of clarity in the Company policy. The Company policy did not clearly articulate the process owners by activity and was updated in Q4 2023, therefore responsible parties were not aware of this required activity. Effect Lack of executing this control could result in ineligible costs being submitted for payment and jobs going above the agreed upon budget. Questioned Costs None noted. Recommendation We recommend the Company review their policies and ensure appropriate communication and coordination amongst relevant parties to ensure the budget to actual review is performed according to policy and appropriate documentation is maintained. This is a repeat finding of 2022-002, which continued to remain open during FY2023. Management’ Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report.
Cluster: Research and Development Supporting Agency: Department of Commerce, Department of Energy, and Department of Human and Health Services Award Names: Standards/Guidance for Rapid Qualification of Metal-Based Additive Manufacturing, Accelerating Commercial Maritime Demonstration Projects for Advanced Nuclear Reactor Technologies, Safety and Health Risks in Energy Transition for the Commercial Fishing Industry, The NASA Floater: 15MW Ultra-lightweight Concrete Hull with Sea-Water Ballast Tuned Mass Dampers, Scale model Experiments for Co-Designed FOWTs Supporting A High-Capacity (15 MW) Turbine, Demonstrating a Reduced-Footprint Synthetic Rope Mooring System that Minimizes Fishing Impacts and Costs for a 10MW+ Floating Wind Turbine Award Numbers: 70NANB21H038, DE-NE0009226, U01OH012502, UMS-1258, ABS-061720, and FOA- 2236 Assistance Listing Title: National Institute of Standards and Technology, Office of Nuclear Energy, Advanced Research Projects Agency, Office of Energy Efficiency and Renewable Energy, Center for Disease Control and Prevention (CDC) Assistance Listing Number: 11.609, 81.121, 81.135, 81.087, 93.262 Award Year: FY 2023 Criteria 2 CFR 200.303 notes that a non-Federal entity must: 1. Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2.Evaluate and monitor the non-Federal entity’s compliance with statutes, regulations, and the terms and conditions of Federal awards. We note that with regards to the Company’s internal controls over Federal awards, a monthly budget to actual review is to be performed and review evidenced for each grant to monitor grant activity, including allowability. Condition We selected 6 quarters out of a population of 61 quarters across the Research and Development Cluster awards for testing to evidence that a budget to actual review was being performed, as required by Company policy. Through our testing, we noted 6 instances where appropriate supporting documentation was not maintained to support that the budget to actual review was performed. We noted through inquiry of management that for each selection, a review of expenses was performed but evidence was not formally maintained of the budget to actual review. However, when reviewing the award budget and cumulative expenses incurred on the award for each selection, it was noted that each quarter selected was within budget. Cause The Company indicated budget to actual monitoring and reviews were not consistently performed due to a lack of clarity in the Company policy. The Company policy did not clearly articulate the process owners by activity and was updated in Q4 2023, therefore responsible parties were not aware of this required activity. Effect Lack of executing this control could result in ineligible costs being submitted for payment and jobs going above the agreed upon budget. Questioned Costs None noted. Recommendation We recommend the Company review their policies and ensure appropriate communication and coordination amongst relevant parties to ensure the budget to actual review is performed according to policy and appropriate documentation is maintained. This is a repeat finding of 2022-002, which continued to remain open during FY2023. Management’ Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report.
Cluster: Research and Development Supporting Agency: Department of Commerce, Department of Energy, and Department of Human and Health Services Award Names: Standards/Guidance for Rapid Qualification of Metal-Based Additive Manufacturing, Accelerating Commercial Maritime Demonstration Projects for Advanced Nuclear Reactor Technologies, Safety and Health Risks in Energy Transition for the Commercial Fishing Industry, The NASA Floater: 15MW Ultra-lightweight Concrete Hull with Sea-Water Ballast Tuned Mass Dampers, Scale model Experiments for Co-Designed FOWTs Supporting A High-Capacity (15 MW) Turbine, Demonstrating a Reduced-Footprint Synthetic Rope Mooring System that Minimizes Fishing Impacts and Costs for a 10MW+ Floating Wind Turbine Award Numbers: 70NANB21H038, DE-NE0009226, U01OH012502, UMS-1258, ABS-061720, and FOA- 2236 Assistance Listing Title: National Institute of Standards and Technology, Office of Nuclear Energy, Advanced Research Projects Agency, Office of Energy Efficiency and Renewable Energy, Center for Disease Control and Prevention (CDC) Assistance Listing Number: 11.609, 81.121, 81.135, 81.087, 93.262 Award Year: FY 2023 Criteria 2 CFR 200.303 notes that a non-Federal entity must: 1. Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2.Evaluate and monitor the non-Federal entity’s compliance with statutes, regulations, and the terms and conditions of Federal awards. We note that with regards to the Company’s internal controls over Federal awards, a monthly budget to actual review is to be performed and review evidenced for each grant to monitor grant activity, including allowability. Condition We selected 6 quarters out of a population of 61 quarters across the Research and Development Cluster awards for testing to evidence that a budget to actual review was being performed, as required by Company policy. Through our testing, we noted 6 instances where appropriate supporting documentation was not maintained to support that the budget to actual review was performed. We noted through inquiry of management that for each selection, a review of expenses was performed but evidence was not formally maintained of the budget to actual review. However, when reviewing the award budget and cumulative expenses incurred on the award for each selection, it was noted that each quarter selected was within budget. Cause The Company indicated budget to actual monitoring and reviews were not consistently performed due to a lack of clarity in the Company policy. The Company policy did not clearly articulate the process owners by activity and was updated in Q4 2023, therefore responsible parties were not aware of this required activity. Effect Lack of executing this control could result in ineligible costs being submitted for payment and jobs going above the agreed upon budget. Questioned Costs None noted. Recommendation We recommend the Company review their policies and ensure appropriate communication and coordination amongst relevant parties to ensure the budget to actual review is performed according to policy and appropriate documentation is maintained. This is a repeat finding of 2022-002, which continued to remain open during FY2023. Management’ Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report.
Cluster: Research and Development Supporting Agency: Department of Commerce, Department of Energy, and Department of Human and Health Services Award Names: Standards/Guidance for Rapid Qualification of Metal-Based Additive Manufacturing, Accelerating Commercial Maritime Demonstration Projects for Advanced Nuclear Reactor Technologies, Safety and Health Risks in Energy Transition for the Commercial Fishing Industry, The NASA Floater: 15MW Ultra-lightweight Concrete Hull with Sea-Water Ballast Tuned Mass Dampers, Scale model Experiments for Co-Designed FOWTs Supporting A High-Capacity (15 MW) Turbine, Demonstrating a Reduced-Footprint Synthetic Rope Mooring System that Minimizes Fishing Impacts and Costs for a 10MW+ Floating Wind Turbine Award Numbers: 70NANB21H038, DE-NE0009226, U01OH012502, UMS-1258, ABS-061720, and FOA- 2236 Assistance Listing Title: National Institute of Standards and Technology, Office of Nuclear Energy, Advanced Research Projects Agency, Office of Energy Efficiency and Renewable Energy, Center for Disease Control and Prevention (CDC) Assistance Listing Number: 11.609, 81.121, 81.135, 81.087, 93.262 Award Year: FY 2023 Criteria 2 CFR 200.303 notes that a non-Federal entity must: 1. Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2.Evaluate and monitor the non-Federal entity’s compliance with statutes, regulations, and the terms and conditions of Federal awards. We note that with regards to the Company’s internal controls over Federal awards, a monthly budget to actual review is to be performed and review evidenced for each grant to monitor grant activity, including allowability. Condition We selected 6 quarters out of a population of 61 quarters across the Research and Development Cluster awards for testing to evidence that a budget to actual review was being performed, as required by Company policy. Through our testing, we noted 6 instances where appropriate supporting documentation was not maintained to support that the budget to actual review was performed. We noted through inquiry of management that for each selection, a review of expenses was performed but evidence was not formally maintained of the budget to actual review. However, when reviewing the award budget and cumulative expenses incurred on the award for each selection, it was noted that each quarter selected was within budget. Cause The Company indicated budget to actual monitoring and reviews were not consistently performed due to a lack of clarity in the Company policy. The Company policy did not clearly articulate the process owners by activity and was updated in Q4 2023, therefore responsible parties were not aware of this required activity. Effect Lack of executing this control could result in ineligible costs being submitted for payment and jobs going above the agreed upon budget. Questioned Costs None noted. Recommendation We recommend the Company review their policies and ensure appropriate communication and coordination amongst relevant parties to ensure the budget to actual review is performed according to policy and appropriate documentation is maintained. This is a repeat finding of 2022-002, which continued to remain open during FY2023. Management’ Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report.