Audit 318055

FY End
2022-12-31
Total Expended
$1.34M
Findings
84
Programs
3
Year: 2022 Accepted: 2024-08-28

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
485286 2022-003 Material Weakness Yes P
485287 2022-004 Significant Deficiency Yes A
485288 2022-005 Significant Deficiency Yes I
485289 2022-003 Material Weakness Yes P
485290 2022-004 Significant Deficiency Yes A
485291 2022-005 Significant Deficiency Yes I
485292 2022-003 Material Weakness Yes P
485293 2022-004 Significant Deficiency Yes A
485294 2022-005 Significant Deficiency Yes I
485295 2022-003 Material Weakness Yes P
485296 2022-005 Significant Deficiency Yes I
485297 2022-003 Material Weakness Yes P
485298 2022-005 Significant Deficiency Yes I
485299 2022-003 Material Weakness Yes P
485300 2022-004 Significant Deficiency Yes A
485301 2022-005 Significant Deficiency Yes I
485302 2022-003 Material Weakness Yes P
485303 2022-005 Significant Deficiency Yes I
485304 2022-003 Material Weakness Yes P
485305 2022-005 Significant Deficiency Yes I
485306 2022-003 Material Weakness Yes P
485307 2022-004 Significant Deficiency Yes A
485308 2022-005 Significant Deficiency Yes I
485309 2022-003 Material Weakness Yes P
485310 2022-005 Significant Deficiency Yes I
485311 2022-003 Material Weakness Yes P
485312 2022-005 Significant Deficiency Yes I
485313 2022-003 Material Weakness Yes P
485314 2022-004 Significant Deficiency Yes A
485315 2022-005 Significant Deficiency Yes I
485316 2022-003 Material Weakness Yes P
485317 2022-004 Significant Deficiency Yes A
485318 2022-005 Significant Deficiency Yes I
485319 2022-005 Significant Deficiency Yes I
485320 2022-004 Significant Deficiency Yes A
485321 2022-005 Significant Deficiency Yes I
485322 2022-003 Material Weakness Yes P
485323 2022-005 Significant Deficiency Yes I
485324 2022-005 Significant Deficiency Yes I
485325 2022-005 Significant Deficiency Yes I
485326 2022-003 Material Weakness Yes P
485327 2022-005 Significant Deficiency Yes I
1061728 2022-003 Material Weakness Yes P
1061729 2022-004 Significant Deficiency Yes A
1061730 2022-005 Significant Deficiency Yes I
1061731 2022-003 Material Weakness Yes P
1061732 2022-004 Significant Deficiency Yes A
1061733 2022-005 Significant Deficiency Yes I
1061734 2022-003 Material Weakness Yes P
1061735 2022-004 Significant Deficiency Yes A
1061736 2022-005 Significant Deficiency Yes I
1061737 2022-003 Material Weakness Yes P
1061738 2022-005 Significant Deficiency Yes I
1061739 2022-003 Material Weakness Yes P
1061740 2022-005 Significant Deficiency Yes I
1061741 2022-003 Material Weakness Yes P
1061742 2022-004 Significant Deficiency Yes A
1061743 2022-005 Significant Deficiency Yes I
1061744 2022-003 Material Weakness Yes P
1061745 2022-005 Significant Deficiency Yes I
1061746 2022-003 Material Weakness Yes P
1061747 2022-005 Significant Deficiency Yes I
1061748 2022-003 Material Weakness Yes P
1061749 2022-004 Significant Deficiency Yes A
1061750 2022-005 Significant Deficiency Yes I
1061751 2022-003 Material Weakness Yes P
1061752 2022-005 Significant Deficiency Yes I
1061753 2022-003 Material Weakness Yes P
1061754 2022-005 Significant Deficiency Yes I
1061755 2022-003 Material Weakness Yes P
1061756 2022-004 Significant Deficiency Yes A
1061757 2022-005 Significant Deficiency Yes I
1061758 2022-003 Material Weakness Yes P
1061759 2022-004 Significant Deficiency Yes A
1061760 2022-005 Significant Deficiency Yes I
1061761 2022-005 Significant Deficiency Yes I
1061762 2022-004 Significant Deficiency Yes A
1061763 2022-005 Significant Deficiency Yes I
1061764 2022-003 Material Weakness Yes P
1061765 2022-005 Significant Deficiency Yes I
1061766 2022-005 Significant Deficiency Yes I
1061767 2022-005 Significant Deficiency Yes I
1061768 2022-003 Material Weakness Yes P
1061769 2022-005 Significant Deficiency Yes I

Programs

ALN Program Spent Major Findings
47.076 Education and Human Resources $132,634 Yes 3
43.001 Science $31,610 Yes 2
47.049 Mathematical and Physical Sciences $11,303 Yes 2

Contacts

Name Title Type
YRLVBH8FJ9L6 Michael Brosnan Auditee
3012093301 Gary Staples Auditor
No contacts on file

Notes to SEFA

Title: Note 1. Basis of Preparation Accounting Policies: Expenses reported on the Schedule are reported on the accrual basis of accounting. Such expenses are recognized following the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, Audit Requirements for Federal Awards (Uniform Guidance), wherein certain types of expenses are not allowable or are limited as reported as expenses in prior years. AAPT has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: Several awards span multiple years, and awards contain diferring cost rates. The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes the Federal award activity of AAPT under programs of the federal government for the fiscal year ended December 31, 2022. Information in the Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The Schedule presents only a selected portion of the operations of AAPT; accordingly, it is not intended to and does not present the financial position, changes in net assets or cash flows of AAPT.
Title: Note 2. Summary of Significant Accounting Policies Accounting Policies: Expenses reported on the Schedule are reported on the accrual basis of accounting. Such expenses are recognized following the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, Audit Requirements for Federal Awards (Uniform Guidance), wherein certain types of expenses are not allowable or are limited as reported as expenses in prior years. AAPT has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: Several awards span multiple years, and awards contain diferring cost rates. Expenses reported on the Schedule are reported on the accrual basis of accounting. Such expenses are recognized following the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, Audit Requirements for Federal Awards (Uniform Guidance), wherein certain types of expenses are not allowable or are limited as reported as expenses in prior years. AAPT has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance.
Title: Note 3. Program Income Accounting Policies: Expenses reported on the Schedule are reported on the accrual basis of accounting. Such expenses are recognized following the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, Audit Requirements for Federal Awards (Uniform Guidance), wherein certain types of expenses are not allowable or are limited as reported as expenses in prior years. AAPT has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: Several awards span multiple years, and awards contain diferring cost rates. Title 2 U.S. Code of Federal Regulations (CFR) Part 200.80 defines program income as gross income earned by the non-Federal entity that is directly generated by a supported activity or earned as a result of the Federal award during the period of performance. Income earned after the end of the period of performance for the Federal award is excluded unless the Federal awarding agency regulations or the terms and conditions of the Federal award provide otherwise. Program income was earned during 2022 related to the following grants: Enhancing Undergraduate STEM Education: Workshops and Learning Communities for Physics and Astronomy Faculty: $24,750 Community Sourcing of Introductory Physics for the Life Sciences: 2,286 Workshops for Faculty and Staff Development in Implementing Physics Advanced Laboratory Experiments: 18,650 Empowering Diverse Voices to Communicate Science: 15,000 Advancing the Integration of Interdisciplinary Computation Thinking in the Physical Sciences and Life Sciences: 380 Total Program Income: $61,066

Finding Details

Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-004: Payroll Significant Deficiency Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): As noted in 2 CFR 200.303 “The non-Federal entity must 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).” Condition: Payroll approvals for individuals are not always made by individuals who are the employee’s supervisors or are otherwise knowledgeable about their level of effort during the payroll periods paid for. Cause: AAPT did not appropriately assign or ensure approval by payroll approvers based on who supervised or was otherwise knowledgeable of employee activity on federal grants. Effect or Potential Effect: Without an individual knowledgeable of an individual employee’s level of effort approving the time charged there is a greater risk that payroll payments are applied to a federal grant improperly, or leave is otherwise improperly omitted or overapplied to the individual’s leave balance. Questioned Costs: None noted. Identification as a Repeat Finding, if Applicable: 2021-004. Recommendation: We recommend that AAPT change the designated approver for certain employees for whom the designated approver is not the employee’s supervisor or is not otherwise aware of the employee’s work efforts. Views of Responsible Officials and Planned Corrective Actions: AAPT has made changes to correctly reflect the employee’s assigned supervisor based on the position and job duties of the employees. Anticipated Completion Date: 04/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-004: Payroll Significant Deficiency Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): As noted in 2 CFR 200.303 “The non-Federal entity must 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).” Condition: Payroll approvals for individuals are not always made by individuals who are the employee’s supervisors or are otherwise knowledgeable about their level of effort during the payroll periods paid for. Cause: AAPT did not appropriately assign or ensure approval by payroll approvers based on who supervised or was otherwise knowledgeable of employee activity on federal grants. Effect or Potential Effect: Without an individual knowledgeable of an individual employee’s level of effort approving the time charged there is a greater risk that payroll payments are applied to a federal grant improperly, or leave is otherwise improperly omitted or overapplied to the individual’s leave balance. Questioned Costs: None noted. Identification as a Repeat Finding, if Applicable: 2021-004. Recommendation: We recommend that AAPT change the designated approver for certain employees for whom the designated approver is not the employee’s supervisor or is not otherwise aware of the employee’s work efforts. Views of Responsible Officials and Planned Corrective Actions: AAPT has made changes to correctly reflect the employee’s assigned supervisor based on the position and job duties of the employees. Anticipated Completion Date: 04/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-004: Payroll Significant Deficiency Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): As noted in 2 CFR 200.303 “The non-Federal entity must 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).” Condition: Payroll approvals for individuals are not always made by individuals who are the employee’s supervisors or are otherwise knowledgeable about their level of effort during the payroll periods paid for. Cause: AAPT did not appropriately assign or ensure approval by payroll approvers based on who supervised or was otherwise knowledgeable of employee activity on federal grants. Effect or Potential Effect: Without an individual knowledgeable of an individual employee’s level of effort approving the time charged there is a greater risk that payroll payments are applied to a federal grant improperly, or leave is otherwise improperly omitted or overapplied to the individual’s leave balance. Questioned Costs: None noted. Identification as a Repeat Finding, if Applicable: 2021-004. Recommendation: We recommend that AAPT change the designated approver for certain employees for whom the designated approver is not the employee’s supervisor or is not otherwise aware of the employee’s work efforts. Views of Responsible Officials and Planned Corrective Actions: AAPT has made changes to correctly reflect the employee’s assigned supervisor based on the position and job duties of the employees. Anticipated Completion Date: 04/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-004: Payroll Significant Deficiency Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): As noted in 2 CFR 200.303 “The non-Federal entity must 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).” Condition: Payroll approvals for individuals are not always made by individuals who are the employee’s supervisors or are otherwise knowledgeable about their level of effort during the payroll periods paid for. Cause: AAPT did not appropriately assign or ensure approval by payroll approvers based on who supervised or was otherwise knowledgeable of employee activity on federal grants. Effect or Potential Effect: Without an individual knowledgeable of an individual employee’s level of effort approving the time charged there is a greater risk that payroll payments are applied to a federal grant improperly, or leave is otherwise improperly omitted or overapplied to the individual’s leave balance. Questioned Costs: None noted. Identification as a Repeat Finding, if Applicable: 2021-004. Recommendation: We recommend that AAPT change the designated approver for certain employees for whom the designated approver is not the employee’s supervisor or is not otherwise aware of the employee’s work efforts. Views of Responsible Officials and Planned Corrective Actions: AAPT has made changes to correctly reflect the employee’s assigned supervisor based on the position and job duties of the employees. Anticipated Completion Date: 04/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-004: Payroll Significant Deficiency Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): As noted in 2 CFR 200.303 “The non-Federal entity must 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).” Condition: Payroll approvals for individuals are not always made by individuals who are the employee’s supervisors or are otherwise knowledgeable about their level of effort during the payroll periods paid for. Cause: AAPT did not appropriately assign or ensure approval by payroll approvers based on who supervised or was otherwise knowledgeable of employee activity on federal grants. Effect or Potential Effect: Without an individual knowledgeable of an individual employee’s level of effort approving the time charged there is a greater risk that payroll payments are applied to a federal grant improperly, or leave is otherwise improperly omitted or overapplied to the individual’s leave balance. Questioned Costs: None noted. Identification as a Repeat Finding, if Applicable: 2021-004. Recommendation: We recommend that AAPT change the designated approver for certain employees for whom the designated approver is not the employee’s supervisor or is not otherwise aware of the employee’s work efforts. Views of Responsible Officials and Planned Corrective Actions: AAPT has made changes to correctly reflect the employee’s assigned supervisor based on the position and job duties of the employees. Anticipated Completion Date: 04/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-004: Payroll Significant Deficiency Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): As noted in 2 CFR 200.303 “The non-Federal entity must 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).” Condition: Payroll approvals for individuals are not always made by individuals who are the employee’s supervisors or are otherwise knowledgeable about their level of effort during the payroll periods paid for. Cause: AAPT did not appropriately assign or ensure approval by payroll approvers based on who supervised or was otherwise knowledgeable of employee activity on federal grants. Effect or Potential Effect: Without an individual knowledgeable of an individual employee’s level of effort approving the time charged there is a greater risk that payroll payments are applied to a federal grant improperly, or leave is otherwise improperly omitted or overapplied to the individual’s leave balance. Questioned Costs: None noted. Identification as a Repeat Finding, if Applicable: 2021-004. Recommendation: We recommend that AAPT change the designated approver for certain employees for whom the designated approver is not the employee’s supervisor or is not otherwise aware of the employee’s work efforts. Views of Responsible Officials and Planned Corrective Actions: AAPT has made changes to correctly reflect the employee’s assigned supervisor based on the position and job duties of the employees. Anticipated Completion Date: 04/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-004: Payroll Significant Deficiency Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): As noted in 2 CFR 200.303 “The non-Federal entity must 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).” Condition: Payroll approvals for individuals are not always made by individuals who are the employee’s supervisors or are otherwise knowledgeable about their level of effort during the payroll periods paid for. Cause: AAPT did not appropriately assign or ensure approval by payroll approvers based on who supervised or was otherwise knowledgeable of employee activity on federal grants. Effect or Potential Effect: Without an individual knowledgeable of an individual employee’s level of effort approving the time charged there is a greater risk that payroll payments are applied to a federal grant improperly, or leave is otherwise improperly omitted or overapplied to the individual’s leave balance. Questioned Costs: None noted. Identification as a Repeat Finding, if Applicable: 2021-004. Recommendation: We recommend that AAPT change the designated approver for certain employees for whom the designated approver is not the employee’s supervisor or is not otherwise aware of the employee’s work efforts. Views of Responsible Officials and Planned Corrective Actions: AAPT has made changes to correctly reflect the employee’s assigned supervisor based on the position and job duties of the employees. Anticipated Completion Date: 04/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-004: Payroll Significant Deficiency Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): As noted in 2 CFR 200.303 “The non-Federal entity must 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).” Condition: Payroll approvals for individuals are not always made by individuals who are the employee’s supervisors or are otherwise knowledgeable about their level of effort during the payroll periods paid for. Cause: AAPT did not appropriately assign or ensure approval by payroll approvers based on who supervised or was otherwise knowledgeable of employee activity on federal grants. Effect or Potential Effect: Without an individual knowledgeable of an individual employee’s level of effort approving the time charged there is a greater risk that payroll payments are applied to a federal grant improperly, or leave is otherwise improperly omitted or overapplied to the individual’s leave balance. Questioned Costs: None noted. Identification as a Repeat Finding, if Applicable: 2021-004. Recommendation: We recommend that AAPT change the designated approver for certain employees for whom the designated approver is not the employee’s supervisor or is not otherwise aware of the employee’s work efforts. Views of Responsible Officials and Planned Corrective Actions: AAPT has made changes to correctly reflect the employee’s assigned supervisor based on the position and job duties of the employees. Anticipated Completion Date: 04/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-004: Payroll Significant Deficiency Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): As noted in 2 CFR 200.303 “The non-Federal entity must 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).” Condition: Payroll approvals for individuals are not always made by individuals who are the employee’s supervisors or are otherwise knowledgeable about their level of effort during the payroll periods paid for. Cause: AAPT did not appropriately assign or ensure approval by payroll approvers based on who supervised or was otherwise knowledgeable of employee activity on federal grants. Effect or Potential Effect: Without an individual knowledgeable of an individual employee’s level of effort approving the time charged there is a greater risk that payroll payments are applied to a federal grant improperly, or leave is otherwise improperly omitted or overapplied to the individual’s leave balance. Questioned Costs: None noted. Identification as a Repeat Finding, if Applicable: 2021-004. Recommendation: We recommend that AAPT change the designated approver for certain employees for whom the designated approver is not the employee’s supervisor or is not otherwise aware of the employee’s work efforts. Views of Responsible Officials and Planned Corrective Actions: AAPT has made changes to correctly reflect the employee’s assigned supervisor based on the position and job duties of the employees. Anticipated Completion Date: 04/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-004: Payroll Significant Deficiency Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): As noted in 2 CFR 200.303 “The non-Federal entity must 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).” Condition: Payroll approvals for individuals are not always made by individuals who are the employee’s supervisors or are otherwise knowledgeable about their level of effort during the payroll periods paid for. Cause: AAPT did not appropriately assign or ensure approval by payroll approvers based on who supervised or was otherwise knowledgeable of employee activity on federal grants. Effect or Potential Effect: Without an individual knowledgeable of an individual employee’s level of effort approving the time charged there is a greater risk that payroll payments are applied to a federal grant improperly, or leave is otherwise improperly omitted or overapplied to the individual’s leave balance. Questioned Costs: None noted. Identification as a Repeat Finding, if Applicable: 2021-004. Recommendation: We recommend that AAPT change the designated approver for certain employees for whom the designated approver is not the employee’s supervisor or is not otherwise aware of the employee’s work efforts. Views of Responsible Officials and Planned Corrective Actions: AAPT has made changes to correctly reflect the employee’s assigned supervisor based on the position and job duties of the employees. Anticipated Completion Date: 04/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-004: Payroll Significant Deficiency Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): As noted in 2 CFR 200.303 “The non-Federal entity must 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).” Condition: Payroll approvals for individuals are not always made by individuals who are the employee’s supervisors or are otherwise knowledgeable about their level of effort during the payroll periods paid for. Cause: AAPT did not appropriately assign or ensure approval by payroll approvers based on who supervised or was otherwise knowledgeable of employee activity on federal grants. Effect or Potential Effect: Without an individual knowledgeable of an individual employee’s level of effort approving the time charged there is a greater risk that payroll payments are applied to a federal grant improperly, or leave is otherwise improperly omitted or overapplied to the individual’s leave balance. Questioned Costs: None noted. Identification as a Repeat Finding, if Applicable: 2021-004. Recommendation: We recommend that AAPT change the designated approver for certain employees for whom the designated approver is not the employee’s supervisor or is not otherwise aware of the employee’s work efforts. Views of Responsible Officials and Planned Corrective Actions: AAPT has made changes to correctly reflect the employee’s assigned supervisor based on the position and job duties of the employees. Anticipated Completion Date: 04/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-004: Payroll Significant Deficiency Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): As noted in 2 CFR 200.303 “The non-Federal entity must 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).” Condition: Payroll approvals for individuals are not always made by individuals who are the employee’s supervisors or are otherwise knowledgeable about their level of effort during the payroll periods paid for. Cause: AAPT did not appropriately assign or ensure approval by payroll approvers based on who supervised or was otherwise knowledgeable of employee activity on federal grants. Effect or Potential Effect: Without an individual knowledgeable of an individual employee’s level of effort approving the time charged there is a greater risk that payroll payments are applied to a federal grant improperly, or leave is otherwise improperly omitted or overapplied to the individual’s leave balance. Questioned Costs: None noted. Identification as a Repeat Finding, if Applicable: 2021-004. Recommendation: We recommend that AAPT change the designated approver for certain employees for whom the designated approver is not the employee’s supervisor or is not otherwise aware of the employee’s work efforts. Views of Responsible Officials and Planned Corrective Actions: AAPT has made changes to correctly reflect the employee’s assigned supervisor based on the position and job duties of the employees. Anticipated Completion Date: 04/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-004: Payroll Significant Deficiency Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): As noted in 2 CFR 200.303 “The non-Federal entity must 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).” Condition: Payroll approvals for individuals are not always made by individuals who are the employee’s supervisors or are otherwise knowledgeable about their level of effort during the payroll periods paid for. Cause: AAPT did not appropriately assign or ensure approval by payroll approvers based on who supervised or was otherwise knowledgeable of employee activity on federal grants. Effect or Potential Effect: Without an individual knowledgeable of an individual employee’s level of effort approving the time charged there is a greater risk that payroll payments are applied to a federal grant improperly, or leave is otherwise improperly omitted or overapplied to the individual’s leave balance. Questioned Costs: None noted. Identification as a Repeat Finding, if Applicable: 2021-004. Recommendation: We recommend that AAPT change the designated approver for certain employees for whom the designated approver is not the employee’s supervisor or is not otherwise aware of the employee’s work efforts. Views of Responsible Officials and Planned Corrective Actions: AAPT has made changes to correctly reflect the employee’s assigned supervisor based on the position and job duties of the employees. Anticipated Completion Date: 04/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-004: Payroll Significant Deficiency Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): As noted in 2 CFR 200.303 “The non-Federal entity must 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).” Condition: Payroll approvals for individuals are not always made by individuals who are the employee’s supervisors or are otherwise knowledgeable about their level of effort during the payroll periods paid for. Cause: AAPT did not appropriately assign or ensure approval by payroll approvers based on who supervised or was otherwise knowledgeable of employee activity on federal grants. Effect or Potential Effect: Without an individual knowledgeable of an individual employee’s level of effort approving the time charged there is a greater risk that payroll payments are applied to a federal grant improperly, or leave is otherwise improperly omitted or overapplied to the individual’s leave balance. Questioned Costs: None noted. Identification as a Repeat Finding, if Applicable: 2021-004. Recommendation: We recommend that AAPT change the designated approver for certain employees for whom the designated approver is not the employee’s supervisor or is not otherwise aware of the employee’s work efforts. Views of Responsible Officials and Planned Corrective Actions: AAPT has made changes to correctly reflect the employee’s assigned supervisor based on the position and job duties of the employees. Anticipated Completion Date: 04/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-004: Payroll Significant Deficiency Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): As noted in 2 CFR 200.303 “The non-Federal entity must 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).” Condition: Payroll approvals for individuals are not always made by individuals who are the employee’s supervisors or are otherwise knowledgeable about their level of effort during the payroll periods paid for. Cause: AAPT did not appropriately assign or ensure approval by payroll approvers based on who supervised or was otherwise knowledgeable of employee activity on federal grants. Effect or Potential Effect: Without an individual knowledgeable of an individual employee’s level of effort approving the time charged there is a greater risk that payroll payments are applied to a federal grant improperly, or leave is otherwise improperly omitted or overapplied to the individual’s leave balance. Questioned Costs: None noted. Identification as a Repeat Finding, if Applicable: 2021-004. Recommendation: We recommend that AAPT change the designated approver for certain employees for whom the designated approver is not the employee’s supervisor or is not otherwise aware of the employee’s work efforts. Views of Responsible Officials and Planned Corrective Actions: AAPT has made changes to correctly reflect the employee’s assigned supervisor based on the position and job duties of the employees. Anticipated Completion Date: 04/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-004: Payroll Significant Deficiency Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): As noted in 2 CFR 200.303 “The non-Federal entity must 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).” Condition: Payroll approvals for individuals are not always made by individuals who are the employee’s supervisors or are otherwise knowledgeable about their level of effort during the payroll periods paid for. Cause: AAPT did not appropriately assign or ensure approval by payroll approvers based on who supervised or was otherwise knowledgeable of employee activity on federal grants. Effect or Potential Effect: Without an individual knowledgeable of an individual employee’s level of effort approving the time charged there is a greater risk that payroll payments are applied to a federal grant improperly, or leave is otherwise improperly omitted or overapplied to the individual’s leave balance. Questioned Costs: None noted. Identification as a Repeat Finding, if Applicable: 2021-004. Recommendation: We recommend that AAPT change the designated approver for certain employees for whom the designated approver is not the employee’s supervisor or is not otherwise aware of the employee’s work efforts. Views of Responsible Officials and Planned Corrective Actions: AAPT has made changes to correctly reflect the employee’s assigned supervisor based on the position and job duties of the employees. Anticipated Completion Date: 04/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-003: Reconciliation of Accounts Material Weakness Federal Programs: Research and Development Cluster: 47.076 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR 200.508 "Auditee Responsibilities" the auditee must prepare appropriate financial statements, including the SEFA (as specifically defined under 2 CFR 200.510 "Financial statements"). Title 2 CFR 200.510 "financial statements" requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements, which must include the total Federal awards expended. In addition, as noted in 2 CFR 200.302 "Financial management", the financial management system of each non-Federal entity must provide for identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received, and records that identify adequately the source and application of funds for federally-funded activities including expenditures. Condition: The year-end schedules for federal grants receivable, and for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Cause: Errors in transferring balances between years occurred, which impacted carry-over amounts and the ending balances as of 12/31/2022. Related to vacation payables, the schedule had not been properly adjusted to account for the number of days in the last pay period. Effect or Potential Effect: Three federal grant accounts were overdrawn as of 12/31/2022, creating a liability to the federal government. The related grant receivable and liability balances were not properly stated before adjustment as a result. Questioned Costs: $115,244. Identification as a Repeat Finding, if Applicable: 2021-003 Recommendation: We recommend AAPT staff prepare schedules used to prepare entries into the accounting information system or which the information in the schedules will otherwise be used to initiate financial transactions, and the transactions and schedules be reviewed by a supervisor. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO