2024-003 Subrecipient Monitoring
Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds
Criteria: Per 2 CFR sections 200.332(d) through (f), a pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and
achieves the performance goals. Per 2 CFR section 200.502(a), the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs which is generally expenditure/expense transactions associated
with awards.
Condition: Subrecipients were not monitored timely enough to perform the necessary evaluation on subrecipient activities or to report expenditures on the schedule of expenditures of federal awards in the appropriate fiscal year.
Cause: UAS did not receive invoices for certain subrecipients until after year-end close and for amounts covering an entire fiscal year and no amounts were accrued.
Effect: Activities of the subrecipient could not be reviewed timely to ensure authorized use or for allowability with grant terms and conditions. Subrecipient expenditures on the schedule of expenditures of federal awards were understated by $344,948.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: Although subrecipient invoices were submitted after year-end close, UAS grant personnel reviewed expenses submitted for allowability and did not identify any disallowed costs.
Repeat Finding: No.
Recommendation: Establish a timeline for subrecipients to provide required reports to UAS in order to receive information during the fiscal year for monitoring during the post-award process. Review grant and subrecipient activity at year-end to evaluate whether all activity has been submitted and recorded.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-003 Subrecipient Monitoring
Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds
Criteria: Per 2 CFR sections 200.332(d) through (f), a pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and
achieves the performance goals. Per 2 CFR section 200.502(a), the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs which is generally expenditure/expense transactions associated
with awards.
Condition: Subrecipients were not monitored timely enough to perform the necessary evaluation on subrecipient activities or to report expenditures on the schedule of expenditures of federal awards in the appropriate fiscal year.
Cause: UAS did not receive invoices for certain subrecipients until after year-end close and for amounts covering an entire fiscal year and no amounts were accrued.
Effect: Activities of the subrecipient could not be reviewed timely to ensure authorized use or for allowability with grant terms and conditions. Subrecipient expenditures on the schedule of expenditures of federal awards were understated by $344,948.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: Although subrecipient invoices were submitted after year-end close, UAS grant personnel reviewed expenses submitted for allowability and did not identify any disallowed costs.
Repeat Finding: No.
Recommendation: Establish a timeline for subrecipients to provide required reports to UAS in order to receive information during the fiscal year for monitoring during the post-award process. Review grant and subrecipient activity at year-end to evaluate whether all activity has been submitted and recorded.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-003 Subrecipient Monitoring
Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds
Criteria: Per 2 CFR sections 200.332(d) through (f), a pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and
achieves the performance goals. Per 2 CFR section 200.502(a), the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs which is generally expenditure/expense transactions associated
with awards.
Condition: Subrecipients were not monitored timely enough to perform the necessary evaluation on subrecipient activities or to report expenditures on the schedule of expenditures of federal awards in the appropriate fiscal year.
Cause: UAS did not receive invoices for certain subrecipients until after year-end close and for amounts covering an entire fiscal year and no amounts were accrued.
Effect: Activities of the subrecipient could not be reviewed timely to ensure authorized use or for allowability with grant terms and conditions. Subrecipient expenditures on the schedule of expenditures of federal awards were understated by $344,948.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: Although subrecipient invoices were submitted after year-end close, UAS grant personnel reviewed expenses submitted for allowability and did not identify any disallowed costs.
Repeat Finding: No.
Recommendation: Establish a timeline for subrecipients to provide required reports to UAS in order to receive information during the fiscal year for monitoring during the post-award process. Review grant and subrecipient activity at year-end to evaluate whether all activity has been submitted and recorded.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-003 Subrecipient Monitoring
Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds
Criteria: Per 2 CFR sections 200.332(d) through (f), a pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and
achieves the performance goals. Per 2 CFR section 200.502(a), the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs which is generally expenditure/expense transactions associated
with awards.
Condition: Subrecipients were not monitored timely enough to perform the necessary evaluation on subrecipient activities or to report expenditures on the schedule of expenditures of federal awards in the appropriate fiscal year.
Cause: UAS did not receive invoices for certain subrecipients until after year-end close and for amounts covering an entire fiscal year and no amounts were accrued.
Effect: Activities of the subrecipient could not be reviewed timely to ensure authorized use or for allowability with grant terms and conditions. Subrecipient expenditures on the schedule of expenditures of federal awards were understated by $344,948.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: Although subrecipient invoices were submitted after year-end close, UAS grant personnel reviewed expenses submitted for allowability and did not identify any disallowed costs.
Repeat Finding: No.
Recommendation: Establish a timeline for subrecipients to provide required reports to UAS in order to receive information during the fiscal year for monitoring during the post-award process. Review grant and subrecipient activity at year-end to evaluate whether all activity has been submitted and recorded.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-004 Payroll Allocation
Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds, 84.047 TRIO Cluster – TRIO-Upward Bound
Criteria: Per 2 CFR section 200.405, a cost is allocable to a particular Federal award if the goods or services involved are chargeable or assignable to that Federal award in accordance with relative benefits received, which can be met if the cost is incurred specifically for the Federal award.
Condition: A payroll allocation change for an employee working on multiple grants was submitted in April 2024, but allocation was not updated in the payroll system timely.
Cause: Human error and oversight resulted in delays in updating the change in allocation between grants.
Effect: The 21.027 Coronavirus State and Local Fiscal Recovery Funds grant was overcharged by $4,673 for related payroll costs.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: While payroll allocation changes were properly approved in April 2024 and total pay to the employee was correct, human error resulted in delays in updating the change in allocation between grants. When the error was identified, updates were made to the allocation in September 2024.
Repeat Finding: No.
Recommendation: Grant management personnel should enhance review procedures for payroll-related expenditures after grant allocation changes are made to ensure that changes submitted are properly reflected in the accounting records in the appropriate period.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-004 Payroll Allocation
Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds, 84.047 TRIO Cluster – TRIO-Upward Bound
Criteria: Per 2 CFR section 200.405, a cost is allocable to a particular Federal award if the goods or services involved are chargeable or assignable to that Federal award in accordance with relative benefits received, which can be met if the cost is incurred specifically for the Federal award.
Condition: A payroll allocation change for an employee working on multiple grants was submitted in April 2024, but allocation was not updated in the payroll system timely.
Cause: Human error and oversight resulted in delays in updating the change in allocation between grants.
Effect: The 21.027 Coronavirus State and Local Fiscal Recovery Funds grant was overcharged by $4,673 for related payroll costs.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: While payroll allocation changes were properly approved in April 2024 and total pay to the employee was correct, human error resulted in delays in updating the change in allocation between grants. When the error was identified, updates were made to the allocation in September 2024.
Repeat Finding: No.
Recommendation: Grant management personnel should enhance review procedures for payroll-related expenditures after grant allocation changes are made to ensure that changes submitted are properly reflected in the accounting records in the appropriate period.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-004 Payroll Allocation
Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds, 84.047 TRIO Cluster – TRIO-Upward Bound
Criteria: Per 2 CFR section 200.405, a cost is allocable to a particular Federal award if the goods or services involved are chargeable or assignable to that Federal award in accordance with relative benefits received, which can be met if the cost is incurred specifically for the Federal award.
Condition: A payroll allocation change for an employee working on multiple grants was submitted in April 2024, but allocation was not updated in the payroll system timely.
Cause: Human error and oversight resulted in delays in updating the change in allocation between grants.
Effect: The 21.027 Coronavirus State and Local Fiscal Recovery Funds grant was overcharged by $4,673 for related payroll costs.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: While payroll allocation changes were properly approved in April 2024 and total pay to the employee was correct, human error resulted in delays in updating the change in allocation between grants. When the error was identified, updates were made to the allocation in September 2024.
Repeat Finding: No.
Recommendation: Grant management personnel should enhance review procedures for payroll-related expenditures after grant allocation changes are made to ensure that changes submitted are properly reflected in the accounting records in the appropriate period.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-004 Payroll Allocation
Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds, 84.047 TRIO Cluster – TRIO-Upward Bound
Criteria: Per 2 CFR section 200.405, a cost is allocable to a particular Federal award if the goods or services involved are chargeable or assignable to that Federal award in accordance with relative benefits received, which can be met if the cost is incurred specifically for the Federal award.
Condition: A payroll allocation change for an employee working on multiple grants was submitted in April 2024, but allocation was not updated in the payroll system timely.
Cause: Human error and oversight resulted in delays in updating the change in allocation between grants.
Effect: The 21.027 Coronavirus State and Local Fiscal Recovery Funds grant was overcharged by $4,673 for related payroll costs.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: While payroll allocation changes were properly approved in April 2024 and total pay to the employee was correct, human error resulted in delays in updating the change in allocation between grants. When the error was identified, updates were made to the allocation in September 2024.
Repeat Finding: No.
Recommendation: Grant management personnel should enhance review procedures for payroll-related expenditures after grant allocation changes are made to ensure that changes submitted are properly reflected in the accounting records in the appropriate period.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-004 Payroll Allocation
Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds, 84.047 TRIO Cluster – TRIO-Upward Bound
Criteria: Per 2 CFR section 200.405, a cost is allocable to a particular Federal award if the goods or services involved are chargeable or assignable to that Federal award in accordance with relative benefits received, which can be met if the cost is incurred specifically for the Federal award.
Condition: A payroll allocation change for an employee working on multiple grants was submitted in April 2024, but allocation was not updated in the payroll system timely.
Cause: Human error and oversight resulted in delays in updating the change in allocation between grants.
Effect: The 21.027 Coronavirus State and Local Fiscal Recovery Funds grant was overcharged by $4,673 for related payroll costs.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: While payroll allocation changes were properly approved in April 2024 and total pay to the employee was correct, human error resulted in delays in updating the change in allocation between grants. When the error was identified, updates were made to the allocation in September 2024.
Repeat Finding: No.
Recommendation: Grant management personnel should enhance review procedures for payroll-related expenditures after grant allocation changes are made to ensure that changes submitted are properly reflected in the accounting records in the appropriate period.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-004 Payroll Allocation
Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds, 84.047 TRIO Cluster – TRIO-Upward Bound
Criteria: Per 2 CFR section 200.405, a cost is allocable to a particular Federal award if the goods or services involved are chargeable or assignable to that Federal award in accordance with relative benefits received, which can be met if the cost is incurred specifically for the Federal award.
Condition: A payroll allocation change for an employee working on multiple grants was submitted in April 2024, but allocation was not updated in the payroll system timely.
Cause: Human error and oversight resulted in delays in updating the change in allocation between grants.
Effect: The 21.027 Coronavirus State and Local Fiscal Recovery Funds grant was overcharged by $4,673 for related payroll costs.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: While payroll allocation changes were properly approved in April 2024 and total pay to the employee was correct, human error resulted in delays in updating the change in allocation between grants. When the error was identified, updates were made to the allocation in September 2024.
Repeat Finding: No.
Recommendation: Grant management personnel should enhance review procedures for payroll-related expenditures after grant allocation changes are made to ensure that changes submitted are properly reflected in the accounting records in the appropriate period.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-004 Payroll Allocation
Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds, 84.047 TRIO Cluster – TRIO-Upward Bound
Criteria: Per 2 CFR section 200.405, a cost is allocable to a particular Federal award if the goods or services involved are chargeable or assignable to that Federal award in accordance with relative benefits received, which can be met if the cost is incurred specifically for the Federal award.
Condition: A payroll allocation change for an employee working on multiple grants was submitted in April 2024, but allocation was not updated in the payroll system timely.
Cause: Human error and oversight resulted in delays in updating the change in allocation between grants.
Effect: The 21.027 Coronavirus State and Local Fiscal Recovery Funds grant was overcharged by $4,673 for related payroll costs.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: While payroll allocation changes were properly approved in April 2024 and total pay to the employee was correct, human error resulted in delays in updating the change in allocation between grants. When the error was identified, updates were made to the allocation in September 2024.
Repeat Finding: No.
Recommendation: Grant management personnel should enhance review procedures for payroll-related expenditures after grant allocation changes are made to ensure that changes submitted are properly reflected in the accounting records in the appropriate period.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-004 Payroll Allocation
Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds, 84.047 TRIO Cluster – TRIO-Upward Bound
Criteria: Per 2 CFR section 200.405, a cost is allocable to a particular Federal award if the goods or services involved are chargeable or assignable to that Federal award in accordance with relative benefits received, which can be met if the cost is incurred specifically for the Federal award.
Condition: A payroll allocation change for an employee working on multiple grants was submitted in April 2024, but allocation was not updated in the payroll system timely.
Cause: Human error and oversight resulted in delays in updating the change in allocation between grants.
Effect: The 21.027 Coronavirus State and Local Fiscal Recovery Funds grant was overcharged by $4,673 for related payroll costs.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: While payroll allocation changes were properly approved in April 2024 and total pay to the employee was correct, human error resulted in delays in updating the change in allocation between grants. When the error was identified, updates were made to the allocation in September 2024.
Repeat Finding: No.
Recommendation: Grant management personnel should enhance review procedures for payroll-related expenditures after grant allocation changes are made to ensure that changes submitted are properly reflected in the accounting records in the appropriate period.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-004 Payroll Allocation
Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds, 84.047 TRIO Cluster – TRIO-Upward Bound
Criteria: Per 2 CFR section 200.405, a cost is allocable to a particular Federal award if the goods or services involved are chargeable or assignable to that Federal award in accordance with relative benefits received, which can be met if the cost is incurred specifically for the Federal award.
Condition: A payroll allocation change for an employee working on multiple grants was submitted in April 2024, but allocation was not updated in the payroll system timely.
Cause: Human error and oversight resulted in delays in updating the change in allocation between grants.
Effect: The 21.027 Coronavirus State and Local Fiscal Recovery Funds grant was overcharged by $4,673 for related payroll costs.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: While payroll allocation changes were properly approved in April 2024 and total pay to the employee was correct, human error resulted in delays in updating the change in allocation between grants. When the error was identified, updates were made to the allocation in September 2024.
Repeat Finding: No.
Recommendation: Grant management personnel should enhance review procedures for payroll-related expenditures after grant allocation changes are made to ensure that changes submitted are properly reflected in the accounting records in the appropriate period.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-005 Suspension and Debarment
Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds
Criteria: The Uniform Guidance and 2 CFR section 180.300 require that, for covered transactions, the non-Federal entity verify that entities are not suspended, debarred, or otherwise excluded.
Condition: UAS’s suspension and debarment procedures only apply to subrecipient contracts and goods and services obtained via purchase order which allows for covered transactions to occur without sufficient review of entity status if not transacted in one of these two ways.
Cause: UAS’s policy does not define when suspension and debarment procedures should be performed.
Effect: UAS engaged in covered transactions without reviewing the entity’s suspended or debarred status.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: While UAS’s Subrecipient Commitment form and CSU General Provisions for Service Acquisitions referred to in the standard Purchase Order form contain either a self-declaration or suspension and debarment clause, the Contractor Service Agreement
does not include this language. Two covered transactions tested with a Contractor Service Agreement did not appear to be reviewed for suspension and debarment prior to entering the transaction, although did appear to adhere to other applicable procurement
policies. Auditors tested a selection of expenditures to determine if any of the selected vendors were suspended or debarred. None were identified as suspended or debarred in this testing.
Repeat Finding: No.
Recommendation: Enhance the current policy to include checking suspension and debarment status for vendors without a purchase order meeting the covered transaction definition, either through checking SAM Exclusions, obtaining a self-declaration/certification, or by adding a clause or condition to the transaction. Expand the policy to include ongoing monitoring of active vendors by checking for suspension and debarment status on a regular basis, but at least annually.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-005 Suspension and Debarment
Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds
Criteria: The Uniform Guidance and 2 CFR section 180.300 require that, for covered transactions, the non-Federal entity verify that entities are not suspended, debarred, or otherwise excluded.
Condition: UAS’s suspension and debarment procedures only apply to subrecipient contracts and goods and services obtained via purchase order which allows for covered transactions to occur without sufficient review of entity status if not transacted in one of these two ways.
Cause: UAS’s policy does not define when suspension and debarment procedures should be performed.
Effect: UAS engaged in covered transactions without reviewing the entity’s suspended or debarred status.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: While UAS’s Subrecipient Commitment form and CSU General Provisions for Service Acquisitions referred to in the standard Purchase Order form contain either a self-declaration or suspension and debarment clause, the Contractor Service Agreement
does not include this language. Two covered transactions tested with a Contractor Service Agreement did not appear to be reviewed for suspension and debarment prior to entering the transaction, although did appear to adhere to other applicable procurement
policies. Auditors tested a selection of expenditures to determine if any of the selected vendors were suspended or debarred. None were identified as suspended or debarred in this testing.
Repeat Finding: No.
Recommendation: Enhance the current policy to include checking suspension and debarment status for vendors without a purchase order meeting the covered transaction definition, either through checking SAM Exclusions, obtaining a self-declaration/certification, or by adding a clause or condition to the transaction. Expand the policy to include ongoing monitoring of active vendors by checking for suspension and debarment status on a regular basis, but at least annually.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-005 Suspension and Debarment
Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds
Criteria: The Uniform Guidance and 2 CFR section 180.300 require that, for covered transactions, the non-Federal entity verify that entities are not suspended, debarred, or otherwise excluded.
Condition: UAS’s suspension and debarment procedures only apply to subrecipient contracts and goods and services obtained via purchase order which allows for covered transactions to occur without sufficient review of entity status if not transacted in one of these two ways.
Cause: UAS’s policy does not define when suspension and debarment procedures should be performed.
Effect: UAS engaged in covered transactions without reviewing the entity’s suspended or debarred status.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: While UAS’s Subrecipient Commitment form and CSU General Provisions for Service Acquisitions referred to in the standard Purchase Order form contain either a self-declaration or suspension and debarment clause, the Contractor Service Agreement
does not include this language. Two covered transactions tested with a Contractor Service Agreement did not appear to be reviewed for suspension and debarment prior to entering the transaction, although did appear to adhere to other applicable procurement
policies. Auditors tested a selection of expenditures to determine if any of the selected vendors were suspended or debarred. None were identified as suspended or debarred in this testing.
Repeat Finding: No.
Recommendation: Enhance the current policy to include checking suspension and debarment status for vendors without a purchase order meeting the covered transaction definition, either through checking SAM Exclusions, obtaining a self-declaration/certification, or by adding a clause or condition to the transaction. Expand the policy to include ongoing monitoring of active vendors by checking for suspension and debarment status on a regular basis, but at least annually.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-005 Suspension and Debarment
Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds
Criteria: The Uniform Guidance and 2 CFR section 180.300 require that, for covered transactions, the non-Federal entity verify that entities are not suspended, debarred, or otherwise excluded.
Condition: UAS’s suspension and debarment procedures only apply to subrecipient contracts and goods and services obtained via purchase order which allows for covered transactions to occur without sufficient review of entity status if not transacted in one of these two ways.
Cause: UAS’s policy does not define when suspension and debarment procedures should be performed.
Effect: UAS engaged in covered transactions without reviewing the entity’s suspended or debarred status.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: While UAS’s Subrecipient Commitment form and CSU General Provisions for Service Acquisitions referred to in the standard Purchase Order form contain either a self-declaration or suspension and debarment clause, the Contractor Service Agreement
does not include this language. Two covered transactions tested with a Contractor Service Agreement did not appear to be reviewed for suspension and debarment prior to entering the transaction, although did appear to adhere to other applicable procurement
policies. Auditors tested a selection of expenditures to determine if any of the selected vendors were suspended or debarred. None were identified as suspended or debarred in this testing.
Repeat Finding: No.
Recommendation: Enhance the current policy to include checking suspension and debarment status for vendors without a purchase order meeting the covered transaction definition, either through checking SAM Exclusions, obtaining a self-declaration/certification, or by adding a clause or condition to the transaction. Expand the policy to include ongoing monitoring of active vendors by checking for suspension and debarment status on a regular basis, but at least annually.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-005 Suspension and Debarment
Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds
Criteria: The Uniform Guidance and 2 CFR section 180.300 require that, for covered transactions, the non-Federal entity verify that entities are not suspended, debarred, or otherwise excluded.
Condition: UAS’s suspension and debarment procedures only apply to subrecipient contracts and goods and services obtained via purchase order which allows for covered transactions to occur without sufficient review of entity status if not transacted in one of these two ways.
Cause: UAS’s policy does not define when suspension and debarment procedures should be performed.
Effect: UAS engaged in covered transactions without reviewing the entity’s suspended or debarred status.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: While UAS’s Subrecipient Commitment form and CSU General Provisions for Service Acquisitions referred to in the standard Purchase Order form contain either a self-declaration or suspension and debarment clause, the Contractor Service Agreement
does not include this language. Two covered transactions tested with a Contractor Service Agreement did not appear to be reviewed for suspension and debarment prior to entering the transaction, although did appear to adhere to other applicable procurement
policies. Auditors tested a selection of expenditures to determine if any of the selected vendors were suspended or debarred. None were identified as suspended or debarred in this testing.
Repeat Finding: No.
Recommendation: Enhance the current policy to include checking suspension and debarment status for vendors without a purchase order meeting the covered transaction definition, either through checking SAM Exclusions, obtaining a self-declaration/certification, or by adding a clause or condition to the transaction. Expand the policy to include ongoing monitoring of active vendors by checking for suspension and debarment status on a regular basis, but at least annually.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-006 Report Submission Delay
Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds
Criteria: In accordance with 2 CFR 200.328, non-Federal entities must submit financial reports at the interval required by the Federal awarding agency or pass-through entity no later than the specified due date. If a justified request is submitted by a non-Federal entity, the Federal entity may extend the due date for any financial report.
Condition: Two monthly financial reports were submitted after the stated due date.
Cause: Monthly reports were generated prior to the due date, but were not reviewed and approved by the deadline for submission.
Effect: Reports were not submitted to the grantor in a timely manner and requests for extension of the due date were not made.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: In both instances, the reports were submitted within 5 days of the stated due date.
Repeat Finding: No.
Recommendation: Reports should be generated sooner to allow time for sufficient review and approval before the due date. When timely submission may not be possible, UAS should request an extension from the grantor by providing a notice of the delay and rationale for the late report, and, if approved, submit the report by the extended deadline. When extensions are not granted, UAS should submit reports by the initial stated due date.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-006 Report Submission Delay
Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds
Criteria: In accordance with 2 CFR 200.328, non-Federal entities must submit financial reports at the interval required by the Federal awarding agency or pass-through entity no later than the specified due date. If a justified request is submitted by a non-Federal entity, the Federal entity may extend the due date for any financial report.
Condition: Two monthly financial reports were submitted after the stated due date.
Cause: Monthly reports were generated prior to the due date, but were not reviewed and approved by the deadline for submission.
Effect: Reports were not submitted to the grantor in a timely manner and requests for extension of the due date were not made.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: In both instances, the reports were submitted within 5 days of the stated due date.
Repeat Finding: No.
Recommendation: Reports should be generated sooner to allow time for sufficient review and approval before the due date. When timely submission may not be possible, UAS should request an extension from the grantor by providing a notice of the delay and rationale for the late report, and, if approved, submit the report by the extended deadline. When extensions are not granted, UAS should submit reports by the initial stated due date.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-006 Report Submission Delay
Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds
Criteria: In accordance with 2 CFR 200.328, non-Federal entities must submit financial reports at the interval required by the Federal awarding agency or pass-through entity no later than the specified due date. If a justified request is submitted by a non-Federal entity, the Federal entity may extend the due date for any financial report.
Condition: Two monthly financial reports were submitted after the stated due date.
Cause: Monthly reports were generated prior to the due date, but were not reviewed and approved by the deadline for submission.
Effect: Reports were not submitted to the grantor in a timely manner and requests for extension of the due date were not made.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: In both instances, the reports were submitted within 5 days of the stated due date.
Repeat Finding: No.
Recommendation: Reports should be generated sooner to allow time for sufficient review and approval before the due date. When timely submission may not be possible, UAS should request an extension from the grantor by providing a notice of the delay and rationale for the late report, and, if approved, submit the report by the extended deadline. When extensions are not granted, UAS should submit reports by the initial stated due date.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-006 Report Submission Delay
Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds
Criteria: In accordance with 2 CFR 200.328, non-Federal entities must submit financial reports at the interval required by the Federal awarding agency or pass-through entity no later than the specified due date. If a justified request is submitted by a non-Federal entity, the Federal entity may extend the due date for any financial report.
Condition: Two monthly financial reports were submitted after the stated due date.
Cause: Monthly reports were generated prior to the due date, but were not reviewed and approved by the deadline for submission.
Effect: Reports were not submitted to the grantor in a timely manner and requests for extension of the due date were not made.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: In both instances, the reports were submitted within 5 days of the stated due date.
Repeat Finding: No.
Recommendation: Reports should be generated sooner to allow time for sufficient review and approval before the due date. When timely submission may not be possible, UAS should request an extension from the grantor by providing a notice of the delay and rationale for the late report, and, if approved, submit the report by the extended deadline. When extensions are not granted, UAS should submit reports by the initial stated due date.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-003 Subrecipient Monitoring
Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds
Criteria: Per 2 CFR sections 200.332(d) through (f), a pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and
achieves the performance goals. Per 2 CFR section 200.502(a), the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs which is generally expenditure/expense transactions associated
with awards.
Condition: Subrecipients were not monitored timely enough to perform the necessary evaluation on subrecipient activities or to report expenditures on the schedule of expenditures of federal awards in the appropriate fiscal year.
Cause: UAS did not receive invoices for certain subrecipients until after year-end close and for amounts covering an entire fiscal year and no amounts were accrued.
Effect: Activities of the subrecipient could not be reviewed timely to ensure authorized use or for allowability with grant terms and conditions. Subrecipient expenditures on the schedule of expenditures of federal awards were understated by $344,948.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: Although subrecipient invoices were submitted after year-end close, UAS grant personnel reviewed expenses submitted for allowability and did not identify any disallowed costs.
Repeat Finding: No.
Recommendation: Establish a timeline for subrecipients to provide required reports to UAS in order to receive information during the fiscal year for monitoring during the post-award process. Review grant and subrecipient activity at year-end to evaluate whether all activity has been submitted and recorded.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-003 Subrecipient Monitoring
Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds
Criteria: Per 2 CFR sections 200.332(d) through (f), a pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and
achieves the performance goals. Per 2 CFR section 200.502(a), the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs which is generally expenditure/expense transactions associated
with awards.
Condition: Subrecipients were not monitored timely enough to perform the necessary evaluation on subrecipient activities or to report expenditures on the schedule of expenditures of federal awards in the appropriate fiscal year.
Cause: UAS did not receive invoices for certain subrecipients until after year-end close and for amounts covering an entire fiscal year and no amounts were accrued.
Effect: Activities of the subrecipient could not be reviewed timely to ensure authorized use or for allowability with grant terms and conditions. Subrecipient expenditures on the schedule of expenditures of federal awards were understated by $344,948.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: Although subrecipient invoices were submitted after year-end close, UAS grant personnel reviewed expenses submitted for allowability and did not identify any disallowed costs.
Repeat Finding: No.
Recommendation: Establish a timeline for subrecipients to provide required reports to UAS in order to receive information during the fiscal year for monitoring during the post-award process. Review grant and subrecipient activity at year-end to evaluate whether all activity has been submitted and recorded.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-003 Subrecipient Monitoring
Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds
Criteria: Per 2 CFR sections 200.332(d) through (f), a pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and
achieves the performance goals. Per 2 CFR section 200.502(a), the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs which is generally expenditure/expense transactions associated
with awards.
Condition: Subrecipients were not monitored timely enough to perform the necessary evaluation on subrecipient activities or to report expenditures on the schedule of expenditures of federal awards in the appropriate fiscal year.
Cause: UAS did not receive invoices for certain subrecipients until after year-end close and for amounts covering an entire fiscal year and no amounts were accrued.
Effect: Activities of the subrecipient could not be reviewed timely to ensure authorized use or for allowability with grant terms and conditions. Subrecipient expenditures on the schedule of expenditures of federal awards were understated by $344,948.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: Although subrecipient invoices were submitted after year-end close, UAS grant personnel reviewed expenses submitted for allowability and did not identify any disallowed costs.
Repeat Finding: No.
Recommendation: Establish a timeline for subrecipients to provide required reports to UAS in order to receive information during the fiscal year for monitoring during the post-award process. Review grant and subrecipient activity at year-end to evaluate whether all activity has been submitted and recorded.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-003 Subrecipient Monitoring
Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds
Criteria: Per 2 CFR sections 200.332(d) through (f), a pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and
achieves the performance goals. Per 2 CFR section 200.502(a), the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs which is generally expenditure/expense transactions associated
with awards.
Condition: Subrecipients were not monitored timely enough to perform the necessary evaluation on subrecipient activities or to report expenditures on the schedule of expenditures of federal awards in the appropriate fiscal year.
Cause: UAS did not receive invoices for certain subrecipients until after year-end close and for amounts covering an entire fiscal year and no amounts were accrued.
Effect: Activities of the subrecipient could not be reviewed timely to ensure authorized use or for allowability with grant terms and conditions. Subrecipient expenditures on the schedule of expenditures of federal awards were understated by $344,948.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: Although subrecipient invoices were submitted after year-end close, UAS grant personnel reviewed expenses submitted for allowability and did not identify any disallowed costs.
Repeat Finding: No.
Recommendation: Establish a timeline for subrecipients to provide required reports to UAS in order to receive information during the fiscal year for monitoring during the post-award process. Review grant and subrecipient activity at year-end to evaluate whether all activity has been submitted and recorded.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-004 Payroll Allocation
Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds, 84.047 TRIO Cluster – TRIO-Upward Bound
Criteria: Per 2 CFR section 200.405, a cost is allocable to a particular Federal award if the goods or services involved are chargeable or assignable to that Federal award in accordance with relative benefits received, which can be met if the cost is incurred specifically for the Federal award.
Condition: A payroll allocation change for an employee working on multiple grants was submitted in April 2024, but allocation was not updated in the payroll system timely.
Cause: Human error and oversight resulted in delays in updating the change in allocation between grants.
Effect: The 21.027 Coronavirus State and Local Fiscal Recovery Funds grant was overcharged by $4,673 for related payroll costs.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: While payroll allocation changes were properly approved in April 2024 and total pay to the employee was correct, human error resulted in delays in updating the change in allocation between grants. When the error was identified, updates were made to the allocation in September 2024.
Repeat Finding: No.
Recommendation: Grant management personnel should enhance review procedures for payroll-related expenditures after grant allocation changes are made to ensure that changes submitted are properly reflected in the accounting records in the appropriate period.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-004 Payroll Allocation
Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds, 84.047 TRIO Cluster – TRIO-Upward Bound
Criteria: Per 2 CFR section 200.405, a cost is allocable to a particular Federal award if the goods or services involved are chargeable or assignable to that Federal award in accordance with relative benefits received, which can be met if the cost is incurred specifically for the Federal award.
Condition: A payroll allocation change for an employee working on multiple grants was submitted in April 2024, but allocation was not updated in the payroll system timely.
Cause: Human error and oversight resulted in delays in updating the change in allocation between grants.
Effect: The 21.027 Coronavirus State and Local Fiscal Recovery Funds grant was overcharged by $4,673 for related payroll costs.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: While payroll allocation changes were properly approved in April 2024 and total pay to the employee was correct, human error resulted in delays in updating the change in allocation between grants. When the error was identified, updates were made to the allocation in September 2024.
Repeat Finding: No.
Recommendation: Grant management personnel should enhance review procedures for payroll-related expenditures after grant allocation changes are made to ensure that changes submitted are properly reflected in the accounting records in the appropriate period.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-004 Payroll Allocation
Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds, 84.047 TRIO Cluster – TRIO-Upward Bound
Criteria: Per 2 CFR section 200.405, a cost is allocable to a particular Federal award if the goods or services involved are chargeable or assignable to that Federal award in accordance with relative benefits received, which can be met if the cost is incurred specifically for the Federal award.
Condition: A payroll allocation change for an employee working on multiple grants was submitted in April 2024, but allocation was not updated in the payroll system timely.
Cause: Human error and oversight resulted in delays in updating the change in allocation between grants.
Effect: The 21.027 Coronavirus State and Local Fiscal Recovery Funds grant was overcharged by $4,673 for related payroll costs.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: While payroll allocation changes were properly approved in April 2024 and total pay to the employee was correct, human error resulted in delays in updating the change in allocation between grants. When the error was identified, updates were made to the allocation in September 2024.
Repeat Finding: No.
Recommendation: Grant management personnel should enhance review procedures for payroll-related expenditures after grant allocation changes are made to ensure that changes submitted are properly reflected in the accounting records in the appropriate period.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-004 Payroll Allocation
Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds, 84.047 TRIO Cluster – TRIO-Upward Bound
Criteria: Per 2 CFR section 200.405, a cost is allocable to a particular Federal award if the goods or services involved are chargeable or assignable to that Federal award in accordance with relative benefits received, which can be met if the cost is incurred specifically for the Federal award.
Condition: A payroll allocation change for an employee working on multiple grants was submitted in April 2024, but allocation was not updated in the payroll system timely.
Cause: Human error and oversight resulted in delays in updating the change in allocation between grants.
Effect: The 21.027 Coronavirus State and Local Fiscal Recovery Funds grant was overcharged by $4,673 for related payroll costs.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: While payroll allocation changes were properly approved in April 2024 and total pay to the employee was correct, human error resulted in delays in updating the change in allocation between grants. When the error was identified, updates were made to the allocation in September 2024.
Repeat Finding: No.
Recommendation: Grant management personnel should enhance review procedures for payroll-related expenditures after grant allocation changes are made to ensure that changes submitted are properly reflected in the accounting records in the appropriate period.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-004 Payroll Allocation
Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds, 84.047 TRIO Cluster – TRIO-Upward Bound
Criteria: Per 2 CFR section 200.405, a cost is allocable to a particular Federal award if the goods or services involved are chargeable or assignable to that Federal award in accordance with relative benefits received, which can be met if the cost is incurred specifically for the Federal award.
Condition: A payroll allocation change for an employee working on multiple grants was submitted in April 2024, but allocation was not updated in the payroll system timely.
Cause: Human error and oversight resulted in delays in updating the change in allocation between grants.
Effect: The 21.027 Coronavirus State and Local Fiscal Recovery Funds grant was overcharged by $4,673 for related payroll costs.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: While payroll allocation changes were properly approved in April 2024 and total pay to the employee was correct, human error resulted in delays in updating the change in allocation between grants. When the error was identified, updates were made to the allocation in September 2024.
Repeat Finding: No.
Recommendation: Grant management personnel should enhance review procedures for payroll-related expenditures after grant allocation changes are made to ensure that changes submitted are properly reflected in the accounting records in the appropriate period.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-004 Payroll Allocation
Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds, 84.047 TRIO Cluster – TRIO-Upward Bound
Criteria: Per 2 CFR section 200.405, a cost is allocable to a particular Federal award if the goods or services involved are chargeable or assignable to that Federal award in accordance with relative benefits received, which can be met if the cost is incurred specifically for the Federal award.
Condition: A payroll allocation change for an employee working on multiple grants was submitted in April 2024, but allocation was not updated in the payroll system timely.
Cause: Human error and oversight resulted in delays in updating the change in allocation between grants.
Effect: The 21.027 Coronavirus State and Local Fiscal Recovery Funds grant was overcharged by $4,673 for related payroll costs.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: While payroll allocation changes were properly approved in April 2024 and total pay to the employee was correct, human error resulted in delays in updating the change in allocation between grants. When the error was identified, updates were made to the allocation in September 2024.
Repeat Finding: No.
Recommendation: Grant management personnel should enhance review procedures for payroll-related expenditures after grant allocation changes are made to ensure that changes submitted are properly reflected in the accounting records in the appropriate period.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-004 Payroll Allocation
Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds, 84.047 TRIO Cluster – TRIO-Upward Bound
Criteria: Per 2 CFR section 200.405, a cost is allocable to a particular Federal award if the goods or services involved are chargeable or assignable to that Federal award in accordance with relative benefits received, which can be met if the cost is incurred specifically for the Federal award.
Condition: A payroll allocation change for an employee working on multiple grants was submitted in April 2024, but allocation was not updated in the payroll system timely.
Cause: Human error and oversight resulted in delays in updating the change in allocation between grants.
Effect: The 21.027 Coronavirus State and Local Fiscal Recovery Funds grant was overcharged by $4,673 for related payroll costs.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: While payroll allocation changes were properly approved in April 2024 and total pay to the employee was correct, human error resulted in delays in updating the change in allocation between grants. When the error was identified, updates were made to the allocation in September 2024.
Repeat Finding: No.
Recommendation: Grant management personnel should enhance review procedures for payroll-related expenditures after grant allocation changes are made to ensure that changes submitted are properly reflected in the accounting records in the appropriate period.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-004 Payroll Allocation
Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds, 84.047 TRIO Cluster – TRIO-Upward Bound
Criteria: Per 2 CFR section 200.405, a cost is allocable to a particular Federal award if the goods or services involved are chargeable or assignable to that Federal award in accordance with relative benefits received, which can be met if the cost is incurred specifically for the Federal award.
Condition: A payroll allocation change for an employee working on multiple grants was submitted in April 2024, but allocation was not updated in the payroll system timely.
Cause: Human error and oversight resulted in delays in updating the change in allocation between grants.
Effect: The 21.027 Coronavirus State and Local Fiscal Recovery Funds grant was overcharged by $4,673 for related payroll costs.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: While payroll allocation changes were properly approved in April 2024 and total pay to the employee was correct, human error resulted in delays in updating the change in allocation between grants. When the error was identified, updates were made to the allocation in September 2024.
Repeat Finding: No.
Recommendation: Grant management personnel should enhance review procedures for payroll-related expenditures after grant allocation changes are made to ensure that changes submitted are properly reflected in the accounting records in the appropriate period.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-004 Payroll Allocation
Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds, 84.047 TRIO Cluster – TRIO-Upward Bound
Criteria: Per 2 CFR section 200.405, a cost is allocable to a particular Federal award if the goods or services involved are chargeable or assignable to that Federal award in accordance with relative benefits received, which can be met if the cost is incurred specifically for the Federal award.
Condition: A payroll allocation change for an employee working on multiple grants was submitted in April 2024, but allocation was not updated in the payroll system timely.
Cause: Human error and oversight resulted in delays in updating the change in allocation between grants.
Effect: The 21.027 Coronavirus State and Local Fiscal Recovery Funds grant was overcharged by $4,673 for related payroll costs.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: While payroll allocation changes were properly approved in April 2024 and total pay to the employee was correct, human error resulted in delays in updating the change in allocation between grants. When the error was identified, updates were made to the allocation in September 2024.
Repeat Finding: No.
Recommendation: Grant management personnel should enhance review procedures for payroll-related expenditures after grant allocation changes are made to ensure that changes submitted are properly reflected in the accounting records in the appropriate period.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-005 Suspension and Debarment
Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds
Criteria: The Uniform Guidance and 2 CFR section 180.300 require that, for covered transactions, the non-Federal entity verify that entities are not suspended, debarred, or otherwise excluded.
Condition: UAS’s suspension and debarment procedures only apply to subrecipient contracts and goods and services obtained via purchase order which allows for covered transactions to occur without sufficient review of entity status if not transacted in one of these two ways.
Cause: UAS’s policy does not define when suspension and debarment procedures should be performed.
Effect: UAS engaged in covered transactions without reviewing the entity’s suspended or debarred status.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: While UAS’s Subrecipient Commitment form and CSU General Provisions for Service Acquisitions referred to in the standard Purchase Order form contain either a self-declaration or suspension and debarment clause, the Contractor Service Agreement
does not include this language. Two covered transactions tested with a Contractor Service Agreement did not appear to be reviewed for suspension and debarment prior to entering the transaction, although did appear to adhere to other applicable procurement
policies. Auditors tested a selection of expenditures to determine if any of the selected vendors were suspended or debarred. None were identified as suspended or debarred in this testing.
Repeat Finding: No.
Recommendation: Enhance the current policy to include checking suspension and debarment status for vendors without a purchase order meeting the covered transaction definition, either through checking SAM Exclusions, obtaining a self-declaration/certification, or by adding a clause or condition to the transaction. Expand the policy to include ongoing monitoring of active vendors by checking for suspension and debarment status on a regular basis, but at least annually.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-005 Suspension and Debarment
Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds
Criteria: The Uniform Guidance and 2 CFR section 180.300 require that, for covered transactions, the non-Federal entity verify that entities are not suspended, debarred, or otherwise excluded.
Condition: UAS’s suspension and debarment procedures only apply to subrecipient contracts and goods and services obtained via purchase order which allows for covered transactions to occur without sufficient review of entity status if not transacted in one of these two ways.
Cause: UAS’s policy does not define when suspension and debarment procedures should be performed.
Effect: UAS engaged in covered transactions without reviewing the entity’s suspended or debarred status.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: While UAS’s Subrecipient Commitment form and CSU General Provisions for Service Acquisitions referred to in the standard Purchase Order form contain either a self-declaration or suspension and debarment clause, the Contractor Service Agreement
does not include this language. Two covered transactions tested with a Contractor Service Agreement did not appear to be reviewed for suspension and debarment prior to entering the transaction, although did appear to adhere to other applicable procurement
policies. Auditors tested a selection of expenditures to determine if any of the selected vendors were suspended or debarred. None were identified as suspended or debarred in this testing.
Repeat Finding: No.
Recommendation: Enhance the current policy to include checking suspension and debarment status for vendors without a purchase order meeting the covered transaction definition, either through checking SAM Exclusions, obtaining a self-declaration/certification, or by adding a clause or condition to the transaction. Expand the policy to include ongoing monitoring of active vendors by checking for suspension and debarment status on a regular basis, but at least annually.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-005 Suspension and Debarment
Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds
Criteria: The Uniform Guidance and 2 CFR section 180.300 require that, for covered transactions, the non-Federal entity verify that entities are not suspended, debarred, or otherwise excluded.
Condition: UAS’s suspension and debarment procedures only apply to subrecipient contracts and goods and services obtained via purchase order which allows for covered transactions to occur without sufficient review of entity status if not transacted in one of these two ways.
Cause: UAS’s policy does not define when suspension and debarment procedures should be performed.
Effect: UAS engaged in covered transactions without reviewing the entity’s suspended or debarred status.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: While UAS’s Subrecipient Commitment form and CSU General Provisions for Service Acquisitions referred to in the standard Purchase Order form contain either a self-declaration or suspension and debarment clause, the Contractor Service Agreement
does not include this language. Two covered transactions tested with a Contractor Service Agreement did not appear to be reviewed for suspension and debarment prior to entering the transaction, although did appear to adhere to other applicable procurement
policies. Auditors tested a selection of expenditures to determine if any of the selected vendors were suspended or debarred. None were identified as suspended or debarred in this testing.
Repeat Finding: No.
Recommendation: Enhance the current policy to include checking suspension and debarment status for vendors without a purchase order meeting the covered transaction definition, either through checking SAM Exclusions, obtaining a self-declaration/certification, or by adding a clause or condition to the transaction. Expand the policy to include ongoing monitoring of active vendors by checking for suspension and debarment status on a regular basis, but at least annually.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-005 Suspension and Debarment
Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds
Criteria: The Uniform Guidance and 2 CFR section 180.300 require that, for covered transactions, the non-Federal entity verify that entities are not suspended, debarred, or otherwise excluded.
Condition: UAS’s suspension and debarment procedures only apply to subrecipient contracts and goods and services obtained via purchase order which allows for covered transactions to occur without sufficient review of entity status if not transacted in one of these two ways.
Cause: UAS’s policy does not define when suspension and debarment procedures should be performed.
Effect: UAS engaged in covered transactions without reviewing the entity’s suspended or debarred status.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: While UAS’s Subrecipient Commitment form and CSU General Provisions for Service Acquisitions referred to in the standard Purchase Order form contain either a self-declaration or suspension and debarment clause, the Contractor Service Agreement
does not include this language. Two covered transactions tested with a Contractor Service Agreement did not appear to be reviewed for suspension and debarment prior to entering the transaction, although did appear to adhere to other applicable procurement
policies. Auditors tested a selection of expenditures to determine if any of the selected vendors were suspended or debarred. None were identified as suspended or debarred in this testing.
Repeat Finding: No.
Recommendation: Enhance the current policy to include checking suspension and debarment status for vendors without a purchase order meeting the covered transaction definition, either through checking SAM Exclusions, obtaining a self-declaration/certification, or by adding a clause or condition to the transaction. Expand the policy to include ongoing monitoring of active vendors by checking for suspension and debarment status on a regular basis, but at least annually.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-005 Suspension and Debarment
Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds
Criteria: The Uniform Guidance and 2 CFR section 180.300 require that, for covered transactions, the non-Federal entity verify that entities are not suspended, debarred, or otherwise excluded.
Condition: UAS’s suspension and debarment procedures only apply to subrecipient contracts and goods and services obtained via purchase order which allows for covered transactions to occur without sufficient review of entity status if not transacted in one of these two ways.
Cause: UAS’s policy does not define when suspension and debarment procedures should be performed.
Effect: UAS engaged in covered transactions without reviewing the entity’s suspended or debarred status.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: While UAS’s Subrecipient Commitment form and CSU General Provisions for Service Acquisitions referred to in the standard Purchase Order form contain either a self-declaration or suspension and debarment clause, the Contractor Service Agreement
does not include this language. Two covered transactions tested with a Contractor Service Agreement did not appear to be reviewed for suspension and debarment prior to entering the transaction, although did appear to adhere to other applicable procurement
policies. Auditors tested a selection of expenditures to determine if any of the selected vendors were suspended or debarred. None were identified as suspended or debarred in this testing.
Repeat Finding: No.
Recommendation: Enhance the current policy to include checking suspension and debarment status for vendors without a purchase order meeting the covered transaction definition, either through checking SAM Exclusions, obtaining a self-declaration/certification, or by adding a clause or condition to the transaction. Expand the policy to include ongoing monitoring of active vendors by checking for suspension and debarment status on a regular basis, but at least annually.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-006 Report Submission Delay
Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds
Criteria: In accordance with 2 CFR 200.328, non-Federal entities must submit financial reports at the interval required by the Federal awarding agency or pass-through entity no later than the specified due date. If a justified request is submitted by a non-Federal entity, the Federal entity may extend the due date for any financial report.
Condition: Two monthly financial reports were submitted after the stated due date.
Cause: Monthly reports were generated prior to the due date, but were not reviewed and approved by the deadline for submission.
Effect: Reports were not submitted to the grantor in a timely manner and requests for extension of the due date were not made.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: In both instances, the reports were submitted within 5 days of the stated due date.
Repeat Finding: No.
Recommendation: Reports should be generated sooner to allow time for sufficient review and approval before the due date. When timely submission may not be possible, UAS should request an extension from the grantor by providing a notice of the delay and rationale for the late report, and, if approved, submit the report by the extended deadline. When extensions are not granted, UAS should submit reports by the initial stated due date.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-006 Report Submission Delay
Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds
Criteria: In accordance with 2 CFR 200.328, non-Federal entities must submit financial reports at the interval required by the Federal awarding agency or pass-through entity no later than the specified due date. If a justified request is submitted by a non-Federal entity, the Federal entity may extend the due date for any financial report.
Condition: Two monthly financial reports were submitted after the stated due date.
Cause: Monthly reports were generated prior to the due date, but were not reviewed and approved by the deadline for submission.
Effect: Reports were not submitted to the grantor in a timely manner and requests for extension of the due date were not made.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: In both instances, the reports were submitted within 5 days of the stated due date.
Repeat Finding: No.
Recommendation: Reports should be generated sooner to allow time for sufficient review and approval before the due date. When timely submission may not be possible, UAS should request an extension from the grantor by providing a notice of the delay and rationale for the late report, and, if approved, submit the report by the extended deadline. When extensions are not granted, UAS should submit reports by the initial stated due date.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-006 Report Submission Delay
Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds
Criteria: In accordance with 2 CFR 200.328, non-Federal entities must submit financial reports at the interval required by the Federal awarding agency or pass-through entity no later than the specified due date. If a justified request is submitted by a non-Federal entity, the Federal entity may extend the due date for any financial report.
Condition: Two monthly financial reports were submitted after the stated due date.
Cause: Monthly reports were generated prior to the due date, but were not reviewed and approved by the deadline for submission.
Effect: Reports were not submitted to the grantor in a timely manner and requests for extension of the due date were not made.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: In both instances, the reports were submitted within 5 days of the stated due date.
Repeat Finding: No.
Recommendation: Reports should be generated sooner to allow time for sufficient review and approval before the due date. When timely submission may not be possible, UAS should request an extension from the grantor by providing a notice of the delay and rationale for the late report, and, if approved, submit the report by the extended deadline. When extensions are not granted, UAS should submit reports by the initial stated due date.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-006 Report Submission Delay
Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds
Criteria: In accordance with 2 CFR 200.328, non-Federal entities must submit financial reports at the interval required by the Federal awarding agency or pass-through entity no later than the specified due date. If a justified request is submitted by a non-Federal entity, the Federal entity may extend the due date for any financial report.
Condition: Two monthly financial reports were submitted after the stated due date.
Cause: Monthly reports were generated prior to the due date, but were not reviewed and approved by the deadline for submission.
Effect: Reports were not submitted to the grantor in a timely manner and requests for extension of the due date were not made.
Questioned Costs: The conditions did not result in questioned costs greater than $25,000.
Context: In both instances, the reports were submitted within 5 days of the stated due date.
Repeat Finding: No.
Recommendation: Reports should be generated sooner to allow time for sufficient review and approval before the due date. When timely submission may not be possible, UAS should request an extension from the grantor by providing a notice of the delay and rationale for the late report, and, if approved, submit the report by the extended deadline. When extensions are not granted, UAS should submit reports by the initial stated due date.
Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.