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.