Audit 327409

Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 93.242 and 93.853, U.S. Department of Health and Human Services - 47.041 and 47.049, National Science Foundation - 84.326, U.S. Department of Education Federal Award Identification Number and Year - Research and Development Cluster: - 93.242 - 5 F31 MH125541-03 - 93.853 - 5 U01 NS120910 02; 1 R61 NS128232-01 - 47.041 - CMMI 2151465; CBET-2125056 EAGER - 47.049 - CHE 1900097; CHE-1955161 - 84.326 - H326T230006-1- FY24-28 Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.344, a recipient must liquidate all financial obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the federal award and must have controls in place as part of that liquidation process in order to ensure that all costs charged to the grant were incurred during the period of performance. Condition - The University did not complete full grant closeout procedures in a timely manner for 10 out of 25 grants that were tested with a period of performance that ended in the year ended June 30, 2024. For 2 of those 10, there was not an independent review of the closeout checklist performed. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related to timeliness of grant closeout procedures. Context - In all samples tested, grant closeout procedures were completed; however, they were outside of an effective time window in order to meet the CFR requirements. The late reviews occurred between 134 days and 262 days after the period of performance ended. Two of the grant closeout checklists were not reviewed by an independent person once they were prepared. Cause and Effect - The University does have a formal grant closeout process in place, which includes a level of review of the grant checklist complete; however, the procedures were not followed or were misunderstood by certain staff, leading to procedures being completed late and a lack of review. Recommendation - The University should implement additional training over the procedures in place and consider whether any additional controls should be designed to mitigate the risk of procedures and reviews not being done in a timely manner. Views of Responsible Officials and Corrective Action Plan - SRS Accounting works closely with the departments on grant closeouts. Although a checklist was not signed by a supervisor, many of these awards had departmental agreement of final expenses. In two cases, the award was fully spent. System restrictions prevent spending 90 days after the grant end date. Due to department and system controls, no unallowable costs were reported on any award. SRS accounting will provide further award closeout training to its team members. Additionally, SRS Accounting added a supervisory team member, which will help mitigate this situation going forward.

Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 93.242 and 93.853, U.S. Department of Health and Human Services - 47.041 and 47.049, National Science Foundation - 84.326, U.S. Department of Education Federal Award Identification Number and Year - Research and Development Cluster: - 93.242 - 5 F31 MH125541-03 - 93.853 - 5 U01 NS120910 02; 1 R61 NS128232-01 - 47.041 - CMMI 2151465; CBET-2125056 EAGER - 47.049 - CHE 1900097; CHE-1955161 - 84.326 - H326T230006-1- FY24-28 Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.344, a recipient must liquidate all financial obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the federal award and must have controls in place as part of that liquidation process in order to ensure that all costs charged to the grant were incurred during the period of performance. Condition - The University did not complete full grant closeout procedures in a timely manner for 10 out of 25 grants that were tested with a period of performance that ended in the year ended June 30, 2024. For 2 of those 10, there was not an independent review of the closeout checklist performed. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related to timeliness of grant closeout procedures. Context - In all samples tested, grant closeout procedures were completed; however, they were outside of an effective time window in order to meet the CFR requirements. The late reviews occurred between 134 days and 262 days after the period of performance ended. Two of the grant closeout checklists were not reviewed by an independent person once they were prepared. Cause and Effect - The University does have a formal grant closeout process in place, which includes a level of review of the grant checklist complete; however, the procedures were not followed or were misunderstood by certain staff, leading to procedures being completed late and a lack of review. Recommendation - The University should implement additional training over the procedures in place and consider whether any additional controls should be designed to mitigate the risk of procedures and reviews not being done in a timely manner. Views of Responsible Officials and Corrective Action Plan - SRS Accounting works closely with the departments on grant closeouts. Although a checklist was not signed by a supervisor, many of these awards had departmental agreement of final expenses. In two cases, the award was fully spent. System restrictions prevent spending 90 days after the grant end date. Due to department and system controls, no unallowable costs were reported on any award. SRS accounting will provide further award closeout training to its team members. Additionally, SRS Accounting added a supervisory team member, which will help mitigate this situation going forward.

Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 93.242 and 93.853, U.S. Department of Health and Human Services - 47.041 and 47.049, National Science Foundation - 84.326, U.S. Department of Education Federal Award Identification Number and Year - Research and Development Cluster: - 93.242 - 5 F31 MH125541-03 - 93.853 - 5 U01 NS120910 02; 1 R61 NS128232-01 - 47.041 - CMMI 2151465; CBET-2125056 EAGER - 47.049 - CHE 1900097; CHE-1955161 - 84.326 - H326T230006-1- FY24-28 Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.344, a recipient must liquidate all financial obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the federal award and must have controls in place as part of that liquidation process in order to ensure that all costs charged to the grant were incurred during the period of performance. Condition - The University did not complete full grant closeout procedures in a timely manner for 10 out of 25 grants that were tested with a period of performance that ended in the year ended June 30, 2024. For 2 of those 10, there was not an independent review of the closeout checklist performed. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related to timeliness of grant closeout procedures. Context - In all samples tested, grant closeout procedures were completed; however, they were outside of an effective time window in order to meet the CFR requirements. The late reviews occurred between 134 days and 262 days after the period of performance ended. Two of the grant closeout checklists were not reviewed by an independent person once they were prepared. Cause and Effect - The University does have a formal grant closeout process in place, which includes a level of review of the grant checklist complete; however, the procedures were not followed or were misunderstood by certain staff, leading to procedures being completed late and a lack of review. Recommendation - The University should implement additional training over the procedures in place and consider whether any additional controls should be designed to mitigate the risk of procedures and reviews not being done in a timely manner. Views of Responsible Officials and Corrective Action Plan - SRS Accounting works closely with the departments on grant closeouts. Although a checklist was not signed by a supervisor, many of these awards had departmental agreement of final expenses. In two cases, the award was fully spent. System restrictions prevent spending 90 days after the grant end date. Due to department and system controls, no unallowable costs were reported on any award. SRS accounting will provide further award closeout training to its team members. Additionally, SRS Accounting added a supervisory team member, which will help mitigate this situation going forward.

Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 93.242 and 93.853, U.S. Department of Health and Human Services - 47.041 and 47.049, National Science Foundation - 84.326, U.S. Department of Education Federal Award Identification Number and Year - Research and Development Cluster: - 93.242 - 5 F31 MH125541-03 - 93.853 - 5 U01 NS120910 02; 1 R61 NS128232-01 - 47.041 - CMMI 2151465; CBET-2125056 EAGER - 47.049 - CHE 1900097; CHE-1955161 - 84.326 - H326T230006-1- FY24-28 Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.344, a recipient must liquidate all financial obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the federal award and must have controls in place as part of that liquidation process in order to ensure that all costs charged to the grant were incurred during the period of performance. Condition - The University did not complete full grant closeout procedures in a timely manner for 10 out of 25 grants that were tested with a period of performance that ended in the year ended June 30, 2024. For 2 of those 10, there was not an independent review of the closeout checklist performed. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related to timeliness of grant closeout procedures. Context - In all samples tested, grant closeout procedures were completed; however, they were outside of an effective time window in order to meet the CFR requirements. The late reviews occurred between 134 days and 262 days after the period of performance ended. Two of the grant closeout checklists were not reviewed by an independent person once they were prepared. Cause and Effect - The University does have a formal grant closeout process in place, which includes a level of review of the grant checklist complete; however, the procedures were not followed or were misunderstood by certain staff, leading to procedures being completed late and a lack of review. Recommendation - The University should implement additional training over the procedures in place and consider whether any additional controls should be designed to mitigate the risk of procedures and reviews not being done in a timely manner. Views of Responsible Officials and Corrective Action Plan - SRS Accounting works closely with the departments on grant closeouts. Although a checklist was not signed by a supervisor, many of these awards had departmental agreement of final expenses. In two cases, the award was fully spent. System restrictions prevent spending 90 days after the grant end date. Due to department and system controls, no unallowable costs were reported on any award. SRS accounting will provide further award closeout training to its team members. Additionally, SRS Accounting added a supervisory team member, which will help mitigate this situation going forward.

Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 93.242 and 93.853, U.S. Department of Health and Human Services - 47.041 and 47.049, National Science Foundation - 84.326, U.S. Department of Education Federal Award Identification Number and Year - Research and Development Cluster: - 93.242 - 5 F31 MH125541-03 - 93.853 - 5 U01 NS120910 02; 1 R61 NS128232-01 - 47.041 - CMMI 2151465; CBET-2125056 EAGER - 47.049 - CHE 1900097; CHE-1955161 - 84.326 - H326T230006-1- FY24-28 Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.344, a recipient must liquidate all financial obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the federal award and must have controls in place as part of that liquidation process in order to ensure that all costs charged to the grant were incurred during the period of performance. Condition - The University did not complete full grant closeout procedures in a timely manner for 10 out of 25 grants that were tested with a period of performance that ended in the year ended June 30, 2024. For 2 of those 10, there was not an independent review of the closeout checklist performed. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related to timeliness of grant closeout procedures. Context - In all samples tested, grant closeout procedures were completed; however, they were outside of an effective time window in order to meet the CFR requirements. The late reviews occurred between 134 days and 262 days after the period of performance ended. Two of the grant closeout checklists were not reviewed by an independent person once they were prepared. Cause and Effect - The University does have a formal grant closeout process in place, which includes a level of review of the grant checklist complete; however, the procedures were not followed or were misunderstood by certain staff, leading to procedures being completed late and a lack of review. Recommendation - The University should implement additional training over the procedures in place and consider whether any additional controls should be designed to mitigate the risk of procedures and reviews not being done in a timely manner. Views of Responsible Officials and Corrective Action Plan - SRS Accounting works closely with the departments on grant closeouts. Although a checklist was not signed by a supervisor, many of these awards had departmental agreement of final expenses. In two cases, the award was fully spent. System restrictions prevent spending 90 days after the grant end date. Due to department and system controls, no unallowable costs were reported on any award. SRS accounting will provide further award closeout training to its team members. Additionally, SRS Accounting added a supervisory team member, which will help mitigate this situation going forward.

Assistance Listing, Federal Agency, and Program Name - 84.042, U.S. Department of Education, Trio Cluster - Student Support Services Federal Award Identification Number and Year - P042A201799; 2021, 2022, 2023 Pass through Entity - N/A Finding Type - Material noncompliance with laws and regulations Repeat Finding - No Criteria - The requirements for activities allowed or unallowed are contained in program legislation, federal awarding agency regulations, and the terms and conditions of the award. Condition - Through an internal audit review, the University identified costs charged to this program that were determined to be unallowable or questionable. Questioned Costs - $69,353 Identification of How Questioned Costs Were Computed - Specific amounts identified by the University's internal audit (IA) department Context - Of the total questioned costs identified, $5,222 was partially unallowable, $35,335 was questionable, and $28,796 was deemed unallowable. The costs spanned from fiscal year ended June 30, 2022 to fiscal year ended June 30, 2024. At the time of identification, $306 of charges was immediately removed from the grant due to the nature of the costs (personal expenses). The remaining questioned costs, as well as all travel expenditures during that period, are being reviewed by IA in further detail to determine if they are unallowable. Cause and Effect - Despite having controls to review cost allowability, a program manager approved costs for the grant that did not clearly meet the program’s terms and conditions. Recommendation - The University should review its procedures regarding expense review to determine whether any changes need to be made to prevent unallowable costs being charged to the program. Views of Responsible Officials and Planned Corrective Actions The University’s internal audit department identified the noncompliance referenced in this finding. The University promptly informed the sponsor and provided refunds for the inappropriate charges. Staff involved in these improper actions were disciplined up to and including termination. Current staff have been counseled and provided additional training. The University has also instituted an additional review step for all large dollar projects and provides central support for the administration of large grants as needed.

Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 93.242 and 93.853, U.S. Department of Health and Human Services - 47.041 and 47.049, National Science Foundation - 84.326, U.S. Department of Education Federal Award Identification Number and Year - Research and Development Cluster: - 93.242 - 5 F31 MH125541-03 - 93.853 - 5 U01 NS120910 02; 1 R61 NS128232-01 - 47.041 - CMMI 2151465; CBET-2125056 EAGER - 47.049 - CHE 1900097; CHE-1955161 - 84.326 - H326T230006-1- FY24-28 Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.344, a recipient must liquidate all financial obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the federal award and must have controls in place as part of that liquidation process in order to ensure that all costs charged to the grant were incurred during the period of performance. Condition - The University did not complete full grant closeout procedures in a timely manner for 10 out of 25 grants that were tested with a period of performance that ended in the year ended June 30, 2024. For 2 of those 10, there was not an independent review of the closeout checklist performed. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related to timeliness of grant closeout procedures. Context - In all samples tested, grant closeout procedures were completed; however, they were outside of an effective time window in order to meet the CFR requirements. The late reviews occurred between 134 days and 262 days after the period of performance ended. Two of the grant closeout checklists were not reviewed by an independent person once they were prepared. Cause and Effect - The University does have a formal grant closeout process in place, which includes a level of review of the grant checklist complete; however, the procedures were not followed or were misunderstood by certain staff, leading to procedures being completed late and a lack of review. Recommendation - The University should implement additional training over the procedures in place and consider whether any additional controls should be designed to mitigate the risk of procedures and reviews not being done in a timely manner. Views of Responsible Officials and Corrective Action Plan - SRS Accounting works closely with the departments on grant closeouts. Although a checklist was not signed by a supervisor, many of these awards had departmental agreement of final expenses. In two cases, the award was fully spent. System restrictions prevent spending 90 days after the grant end date. Due to department and system controls, no unallowable costs were reported on any award. SRS accounting will provide further award closeout training to its team members. Additionally, SRS Accounting added a supervisory team member, which will help mitigate this situation going forward.

Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 93.242 and 93.853, U.S. Department of Health and Human Services - 47.041 and 47.049, National Science Foundation - 84.326, U.S. Department of Education Federal Award Identification Number and Year - Research and Development Cluster: - 93.242 - 5 F31 MH125541-03 - 93.853 - 5 U01 NS120910 02; 1 R61 NS128232-01 - 47.041 - CMMI 2151465; CBET-2125056 EAGER - 47.049 - CHE 1900097; CHE-1955161 - 84.326 - H326T230006-1- FY24-28 Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.344, a recipient must liquidate all financial obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the federal award and must have controls in place as part of that liquidation process in order to ensure that all costs charged to the grant were incurred during the period of performance. Condition - The University did not complete full grant closeout procedures in a timely manner for 10 out of 25 grants that were tested with a period of performance that ended in the year ended June 30, 2024. For 2 of those 10, there was not an independent review of the closeout checklist performed. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related to timeliness of grant closeout procedures. Context - In all samples tested, grant closeout procedures were completed; however, they were outside of an effective time window in order to meet the CFR requirements. The late reviews occurred between 134 days and 262 days after the period of performance ended. Two of the grant closeout checklists were not reviewed by an independent person once they were prepared. Cause and Effect - The University does have a formal grant closeout process in place, which includes a level of review of the grant checklist complete; however, the procedures were not followed or were misunderstood by certain staff, leading to procedures being completed late and a lack of review. Recommendation - The University should implement additional training over the procedures in place and consider whether any additional controls should be designed to mitigate the risk of procedures and reviews not being done in a timely manner. Views of Responsible Officials and Corrective Action Plan - SRS Accounting works closely with the departments on grant closeouts. Although a checklist was not signed by a supervisor, many of these awards had departmental agreement of final expenses. In two cases, the award was fully spent. System restrictions prevent spending 90 days after the grant end date. Due to department and system controls, no unallowable costs were reported on any award. SRS accounting will provide further award closeout training to its team members. Additionally, SRS Accounting added a supervisory team member, which will help mitigate this situation going forward.

Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 93.242 and 93.853, U.S. Department of Health and Human Services - 47.041 and 47.049, National Science Foundation - 84.326, U.S. Department of Education Federal Award Identification Number and Year - Research and Development Cluster: - 93.242 - 5 F31 MH125541-03 - 93.853 - 5 U01 NS120910 02; 1 R61 NS128232-01 - 47.041 - CMMI 2151465; CBET-2125056 EAGER - 47.049 - CHE 1900097; CHE-1955161 - 84.326 - H326T230006-1- FY24-28 Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.344, a recipient must liquidate all financial obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the federal award and must have controls in place as part of that liquidation process in order to ensure that all costs charged to the grant were incurred during the period of performance. Condition - The University did not complete full grant closeout procedures in a timely manner for 10 out of 25 grants that were tested with a period of performance that ended in the year ended June 30, 2024. For 2 of those 10, there was not an independent review of the closeout checklist performed. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related to timeliness of grant closeout procedures. Context - In all samples tested, grant closeout procedures were completed; however, they were outside of an effective time window in order to meet the CFR requirements. The late reviews occurred between 134 days and 262 days after the period of performance ended. Two of the grant closeout checklists were not reviewed by an independent person once they were prepared. Cause and Effect - The University does have a formal grant closeout process in place, which includes a level of review of the grant checklist complete; however, the procedures were not followed or were misunderstood by certain staff, leading to procedures being completed late and a lack of review. Recommendation - The University should implement additional training over the procedures in place and consider whether any additional controls should be designed to mitigate the risk of procedures and reviews not being done in a timely manner. Views of Responsible Officials and Corrective Action Plan - SRS Accounting works closely with the departments on grant closeouts. Although a checklist was not signed by a supervisor, many of these awards had departmental agreement of final expenses. In two cases, the award was fully spent. System restrictions prevent spending 90 days after the grant end date. Due to department and system controls, no unallowable costs were reported on any award. SRS accounting will provide further award closeout training to its team members. Additionally, SRS Accounting added a supervisory team member, which will help mitigate this situation going forward.

Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 93.242 and 93.853, U.S. Department of Health and Human Services - 47.041 and 47.049, National Science Foundation - 84.326, U.S. Department of Education Federal Award Identification Number and Year - Research and Development Cluster: - 93.242 - 5 F31 MH125541-03 - 93.853 - 5 U01 NS120910 02; 1 R61 NS128232-01 - 47.041 - CMMI 2151465; CBET-2125056 EAGER - 47.049 - CHE 1900097; CHE-1955161 - 84.326 - H326T230006-1- FY24-28 Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.344, a recipient must liquidate all financial obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the federal award and must have controls in place as part of that liquidation process in order to ensure that all costs charged to the grant were incurred during the period of performance. Condition - The University did not complete full grant closeout procedures in a timely manner for 10 out of 25 grants that were tested with a period of performance that ended in the year ended June 30, 2024. For 2 of those 10, there was not an independent review of the closeout checklist performed. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related to timeliness of grant closeout procedures. Context - In all samples tested, grant closeout procedures were completed; however, they were outside of an effective time window in order to meet the CFR requirements. The late reviews occurred between 134 days and 262 days after the period of performance ended. Two of the grant closeout checklists were not reviewed by an independent person once they were prepared. Cause and Effect - The University does have a formal grant closeout process in place, which includes a level of review of the grant checklist complete; however, the procedures were not followed or were misunderstood by certain staff, leading to procedures being completed late and a lack of review. Recommendation - The University should implement additional training over the procedures in place and consider whether any additional controls should be designed to mitigate the risk of procedures and reviews not being done in a timely manner. Views of Responsible Officials and Corrective Action Plan - SRS Accounting works closely with the departments on grant closeouts. Although a checklist was not signed by a supervisor, many of these awards had departmental agreement of final expenses. In two cases, the award was fully spent. System restrictions prevent spending 90 days after the grant end date. Due to department and system controls, no unallowable costs were reported on any award. SRS accounting will provide further award closeout training to its team members. Additionally, SRS Accounting added a supervisory team member, which will help mitigate this situation going forward.

Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 93.242 and 93.853, U.S. Department of Health and Human Services - 47.041 and 47.049, National Science Foundation - 84.326, U.S. Department of Education Federal Award Identification Number and Year - Research and Development Cluster: - 93.242 - 5 F31 MH125541-03 - 93.853 - 5 U01 NS120910 02; 1 R61 NS128232-01 - 47.041 - CMMI 2151465; CBET-2125056 EAGER - 47.049 - CHE 1900097; CHE-1955161 - 84.326 - H326T230006-1- FY24-28 Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.344, a recipient must liquidate all financial obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the federal award and must have controls in place as part of that liquidation process in order to ensure that all costs charged to the grant were incurred during the period of performance. Condition - The University did not complete full grant closeout procedures in a timely manner for 10 out of 25 grants that were tested with a period of performance that ended in the year ended June 30, 2024. For 2 of those 10, there was not an independent review of the closeout checklist performed. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related to timeliness of grant closeout procedures. Context - In all samples tested, grant closeout procedures were completed; however, they were outside of an effective time window in order to meet the CFR requirements. The late reviews occurred between 134 days and 262 days after the period of performance ended. Two of the grant closeout checklists were not reviewed by an independent person once they were prepared. Cause and Effect - The University does have a formal grant closeout process in place, which includes a level of review of the grant checklist complete; however, the procedures were not followed or were misunderstood by certain staff, leading to procedures being completed late and a lack of review. Recommendation - The University should implement additional training over the procedures in place and consider whether any additional controls should be designed to mitigate the risk of procedures and reviews not being done in a timely manner. Views of Responsible Officials and Corrective Action Plan - SRS Accounting works closely with the departments on grant closeouts. Although a checklist was not signed by a supervisor, many of these awards had departmental agreement of final expenses. In two cases, the award was fully spent. System restrictions prevent spending 90 days after the grant end date. Due to department and system controls, no unallowable costs were reported on any award. SRS accounting will provide further award closeout training to its team members. Additionally, SRS Accounting added a supervisory team member, which will help mitigate this situation going forward.

Assistance Listing, Federal Agency, and Program Name - 84.042, U.S. Department of Education, Trio Cluster - Student Support Services Federal Award Identification Number and Year - P042A201799; 2021, 2022, 2023 Pass through Entity - N/A Finding Type - Material noncompliance with laws and regulations Repeat Finding - No Criteria - The requirements for activities allowed or unallowed are contained in program legislation, federal awarding agency regulations, and the terms and conditions of the award. Condition - Through an internal audit review, the University identified costs charged to this program that were determined to be unallowable or questionable. Questioned Costs - $69,353 Identification of How Questioned Costs Were Computed - Specific amounts identified by the University's internal audit (IA) department Context - Of the total questioned costs identified, $5,222 was partially unallowable, $35,335 was questionable, and $28,796 was deemed unallowable. The costs spanned from fiscal year ended June 30, 2022 to fiscal year ended June 30, 2024. At the time of identification, $306 of charges was immediately removed from the grant due to the nature of the costs (personal expenses). The remaining questioned costs, as well as all travel expenditures during that period, are being reviewed by IA in further detail to determine if they are unallowable. Cause and Effect - Despite having controls to review cost allowability, a program manager approved costs for the grant that did not clearly meet the program’s terms and conditions. Recommendation - The University should review its procedures regarding expense review to determine whether any changes need to be made to prevent unallowable costs being charged to the program. Views of Responsible Officials and Planned Corrective Actions The University’s internal audit department identified the noncompliance referenced in this finding. The University promptly informed the sponsor and provided refunds for the inappropriate charges. Staff involved in these improper actions were disciplined up to and including termination. Current staff have been counseled and provided additional training. The University has also instituted an additional review step for all large dollar projects and provides central support for the administration of large grants as needed.