Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-004: Payroll
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1726113 (8/1/2017 – 9/30/2023)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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. Of the 25 individual payroll payments tested to 5 separate individuals, totaling $40,904 charged to federal grants, we identified 16 total payments to 4 separate individuals, totaling $16,226, where the timesheet was approved by the CFO, who we do not consider to be knowledgeable of the employee’s activities during a given pay period. One of these four individuals was a full-time employee and the other three were part-time employees.
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: Not a repeat finding.
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 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-004: Payroll
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1726113 (8/1/2017 – 9/30/2023)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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. Of the 25 individual payroll payments tested to 5 separate individuals, totaling $40,904 charged to federal grants, we identified 16 total payments to 4 separate individuals, totaling $16,226, where the timesheet was approved by the CFO, who we do not consider to be knowledgeable of the employee’s activities during a given pay period. One of these four individuals was a full-time employee and the other three were part-time employees.
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: Not a repeat finding.
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 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-006: Subrecipient Monitoring
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1640791 (9/15/2016 – 8/31/2022)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): As stated in 2 CFR 200.331 part (b), all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring procedures to prescribe to each individual subrecipient.
Condition: During our audit work over subrecipient monitoring, we were unable to verify that pre-award risk assessment procedures were performed. It is our understanding that AAPT has ongoing relationships with these subrecipients and evaluation of these subrecipients' risk is a continual process; however, these procedures were not documented.
Cause: AAPT’s internal policies and procedures governing risk assessment on subrecipient was not performed.
Effect or Potential Effect: AAPT could inadvertently engage in relationships with subrecipients of higher risk without the appropriate level of oversight to ensure subrecipients are expending funds in accordance with the provisions and terms of the subaward.
Questioned Costs: None noted.
Context: Our audit procedures consisted of examining documentation of the subrecipient monitoring process, and evaluating internal controls over the process.
Identification as a Repeat Finding, if Applicable: 2019-005.
Recommendation: We recommend AAPT follow their internal policies and procedures surrounding subrecipients and document the risk assessment criteria for the purpose of determining the expected level of oversight during the period of performance. This evaluation should include a scaling system, such as high, medium or low risk (for example), and the monitoring tools and procedures to be performed at each of these levels (additional training, on-site reviews, types of and frequency of reporting, etc.).
Views of Responsible Officials and Planned Corrective Actions: Management will continue to perform risk assessment procedures and will thoroughly document the processes and evaluations.
Anticipated Completion Date: 12/31/2022
Responsible Official: Michael Brosnan, CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-004: Payroll
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1726113 (8/1/2017 – 9/30/2023)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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. Of the 25 individual payroll payments tested to 5 separate individuals, totaling $40,904 charged to federal grants, we identified 16 total payments to 4 separate individuals, totaling $16,226, where the timesheet was approved by the CFO, who we do not consider to be knowledgeable of the employee’s activities during a given pay period. One of these four individuals was a full-time employee and the other three were part-time employees.
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: Not a repeat finding.
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 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-003: Reconciliation of Accounts
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023)
Material Weakness in Internal Control over Compliance, Material Noncompliance
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, 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 12/31/2020. 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 12/31/2020, 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: $77,113 in total. Assistance listing number 47.076. Of this amount, $62,403 applies to award ID 1505278, which was closed before 1/1/2020 and did not have expenses or drawdowns in 2020 but by the end of 2018 had $138,034 in federal funding provided to AAPT and $75,631 of reimbursable expenses. AAPT had not refunded the overpayment, such as by applying this $62,403 as a reduction in federal reimbursements drawn during 2020. The remaining amounts of $10,654 and $4,056 relate to award IDs 1812860, and 1940925, respectively, and were calculated in the same manner. The period of performance for award ID 1812860 ended on 8/31/2020. Award ID 1940925 was active through 12/31/2020.
Identification as a Repeat Finding, if Applicable: 2019-002
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 $73,057 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by April, 30,2024 The remaining balance was earned in 2021.
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: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-003: Reconciliation of Accounts
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023)
Material Weakness in Internal Control over Compliance, Material Noncompliance
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, 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 12/31/2020. 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 12/31/2020, 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: $77,113 in total. Assistance listing number 47.076. Of this amount, $62,403 applies to award ID 1505278, which was closed before 1/1/2020 and did not have expenses or drawdowns in 2020 but by the end of 2018 had $138,034 in federal funding provided to AAPT and $75,631 of reimbursable expenses. AAPT had not refunded the overpayment, such as by applying this $62,403 as a reduction in federal reimbursements drawn during 2020. The remaining amounts of $10,654 and $4,056 relate to award IDs 1812860, and 1940925, respectively, and were calculated in the same manner. The period of performance for award ID 1812860 ended on 8/31/2020. Award ID 1940925 was active through 12/31/2020.
Identification as a Repeat Finding, if Applicable: 2019-002
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 $73,057 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by April, 30,2024 The remaining balance was earned in 2021.
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: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-004: Payroll
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1726113 (8/1/2017 – 9/30/2023)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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. Of the 25 individual payroll payments tested to 5 separate individuals, totaling $40,904 charged to federal grants, we identified 16 total payments to 4 separate individuals, totaling $16,226, where the timesheet was approved by the CFO, who we do not consider to be knowledgeable of the employee’s activities during a given pay period. One of these four individuals was a full-time employee and the other three were part-time employees.
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: Not a repeat finding.
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 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-004: Payroll
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1726113 (8/1/2017 – 9/30/2023)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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. Of the 25 individual payroll payments tested to 5 separate individuals, totaling $40,904 charged to federal grants, we identified 16 total payments to 4 separate individuals, totaling $16,226, where the timesheet was approved by the CFO, who we do not consider to be knowledgeable of the employee’s activities during a given pay period. One of these four individuals was a full-time employee and the other three were part-time employees.
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: Not a repeat finding.
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 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-006: Subrecipient Monitoring
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1640791 (9/15/2016 – 8/31/2022)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): As stated in 2 CFR 200.331 part (b), all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring procedures to prescribe to each individual subrecipient.
Condition: During our audit work over subrecipient monitoring, we were unable to verify that pre-award risk assessment procedures were performed. It is our understanding that AAPT has ongoing relationships with these subrecipients and evaluation of these subrecipients' risk is a continual process; however, these procedures were not documented.
Cause: AAPT’s internal policies and procedures governing risk assessment on subrecipient was not performed.
Effect or Potential Effect: AAPT could inadvertently engage in relationships with subrecipients of higher risk without the appropriate level of oversight to ensure subrecipients are expending funds in accordance with the provisions and terms of the subaward.
Questioned Costs: None noted.
Context: Our audit procedures consisted of examining documentation of the subrecipient monitoring process, and evaluating internal controls over the process.
Identification as a Repeat Finding, if Applicable: 2019-005.
Recommendation: We recommend AAPT follow their internal policies and procedures surrounding subrecipients and document the risk assessment criteria for the purpose of determining the expected level of oversight during the period of performance. This evaluation should include a scaling system, such as high, medium or low risk (for example), and the monitoring tools and procedures to be performed at each of these levels (additional training, on-site reviews, types of and frequency of reporting, etc.).
Views of Responsible Officials and Planned Corrective Actions: Management will continue to perform risk assessment procedures and will thoroughly document the processes and evaluations.
Anticipated Completion Date: 12/31/2022
Responsible Official: Michael Brosnan, CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-004: Payroll
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1726113 (8/1/2017 – 9/30/2023)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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. Of the 25 individual payroll payments tested to 5 separate individuals, totaling $40,904 charged to federal grants, we identified 16 total payments to 4 separate individuals, totaling $16,226, where the timesheet was approved by the CFO, who we do not consider to be knowledgeable of the employee’s activities during a given pay period. One of these four individuals was a full-time employee and the other three were part-time employees.
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: Not a repeat finding.
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 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-003: Reconciliation of Accounts
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023)
Material Weakness in Internal Control over Compliance, Material Noncompliance
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, 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 12/31/2020. 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 12/31/2020, 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: $77,113 in total. Assistance listing number 47.076. Of this amount, $62,403 applies to award ID 1505278, which was closed before 1/1/2020 and did not have expenses or drawdowns in 2020 but by the end of 2018 had $138,034 in federal funding provided to AAPT and $75,631 of reimbursable expenses. AAPT had not refunded the overpayment, such as by applying this $62,403 as a reduction in federal reimbursements drawn during 2020. The remaining amounts of $10,654 and $4,056 relate to award IDs 1812860, and 1940925, respectively, and were calculated in the same manner. The period of performance for award ID 1812860 ended on 8/31/2020. Award ID 1940925 was active through 12/31/2020.
Identification as a Repeat Finding, if Applicable: 2019-002
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 $73,057 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by April, 30,2024 The remaining balance was earned in 2021.
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: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-003: Reconciliation of Accounts
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023)
Material Weakness in Internal Control over Compliance, Material Noncompliance
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, 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 12/31/2020. 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 12/31/2020, 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: $77,113 in total. Assistance listing number 47.076. Of this amount, $62,403 applies to award ID 1505278, which was closed before 1/1/2020 and did not have expenses or drawdowns in 2020 but by the end of 2018 had $138,034 in federal funding provided to AAPT and $75,631 of reimbursable expenses. AAPT had not refunded the overpayment, such as by applying this $62,403 as a reduction in federal reimbursements drawn during 2020. The remaining amounts of $10,654 and $4,056 relate to award IDs 1812860, and 1940925, respectively, and were calculated in the same manner. The period of performance for award ID 1812860 ended on 8/31/2020. Award ID 1940925 was active through 12/31/2020.
Identification as a Repeat Finding, if Applicable: 2019-002
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 $73,057 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by April, 30,2024 The remaining balance was earned in 2021.
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: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2020-001: State Audit Law and Single Audit Reporting
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per Executive Article 7-A, Section 172-B of New York law, non-profit organizations chartered in the State of New York were required to complete and file their annual financial report including the audit by May 15 of the following year for non-profits with a fiscal year end of December 31st. An automatic six month extension has been granted by the New York State Attorney General’s Charities Bureau to all non-profits since 2015, and for 2020 an additional six months was granted by the New York State Attorney General’s Charities Bureau due to the Covid-19 pandemic. With these two automatic extensions, the due date to file the annual financial report including the audit was May 15, 2022.
Title 2, Part 200 Section 512 of the Code of Federal Regulations states that an auditee’s audit required under Title 2, Part 200 Section 501 must be completed and the data collection form and reporting package submitted within the earlier of 30 days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. As part of memo M 21-20, an automatic extension was granted by the Office of Management and Budget of the Executive Office of the President of the United States that permitted auditees to file their audit required under Title 2, Part 200 Section 501 (single audit) by six months after the normal due date. With this automatic extension, the due date to file the audit was March 31, 2022.
Condition: AAPT did not timely file the audit with the annual financial report with the State of New York. AAPT did not timely file the single audit with the Federal Clearing House.
Cause: AAPT was unable to perform their year-end close timely and retain an auditor in order to have the annual audit completed.
Effect or Potential Effect: New York law permits the State’s Attorney General to revoke non-profit status when audits are not filed timely. Federal awarding agencies may take actions including determining to not award grants to entities who are not compliant with regulations, and audit findings can restrict AAPT's ability to negotiate an indirect cost rate with the Federal government.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Not a repeat finding
Recommendation: We recommend that AAPT implement procedures to enhance its month-end
and year-end close procedures to improve the ability of AAPT to produce financial data to meet the criteria established by Executive Article 7-A, Section 172-B of New York law.
Views of Responsible Officials and Planned Corrective Actions: AAPT has institute new policies and deadlines for staff to submit the required documentation in order for the accounting department to close the monthly books on a more timely and accurate financial statements. The
polices include new staff repercussions for not following the new policies up to termination of employment.
Anticipated Completion Date: October 15, 2024
Responsible Official: Michael Brosnan, CFO
Finding 2020-002: Segregation of Duties
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Material Weakness in Internal Controls Over Compliance, Other matters
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: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances.
Cause: Accounting department employees have not been trained to perform tasks that would allow for a proper segregation of duties related to accounting entries. Employees outside of the accounting department are permitted to work from home, which limits the employees who can perform functions such as opening the mail.
Effect or Potential Effect: If any one employee can control all stages of a transaction, defalcations or irregularities could occur and not be detected timely.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: 2019-001
Recommendation: We recommend that AAPT provide training to the Finance and Administration staff so that entries can be subject to supervisory review by an individual knowledgeable as to the propriety of the entries. We recommend that AAPT segregate the ability to initiate and authorize electronic payments. We recommend that an employee outside of the Finance and Administration department open the AAPT mail and create an initial recordation log of checks or cash received.
Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments.
The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024
The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024
The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received.
Anticipated Completion Date: January 2025
Responsible Official: Michael Brosnan, CFO
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
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: 2019-004.
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: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO